Mod 16 - para 2.81

WDC has shown no exceptional circumstances to remove this land from the green belt. The development is for Coventry City Councils needs but there are sites already assessed IN AND around Coventry of lower green belt value which should be used, so why choose Milverton ? The green belt between leamington and Kenilworth is of greater value than other areas closer to Coventry itself so I believe these should be looked at first.

I have lived in Leamington Spa for 22 years, all of this time within half a mile of the land north of Milverton. During this time I have become very familiar with the area, and it is clear to me that 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. There are a number of issues and faults with this proposal as follows:
1. The proposed development is to support Coventry City Council's housing need, but there are sustainable sites closer to Coventry that should be used in preference to the land north of Milverton. I cycle past these sites every week day on the way to Coventry station, using them would reduce unnecessary commuting and prevent even further congestion than already experienced on the Kenilworth road - at peak times a journey that should take ten minutes from Milverton to Coventry already takes half an hour in a car. Further expensive and disruptive road building would be needed, making the plan unworkable.
2. Given house prices in Leamington compared to Coventry, in practice it is unlikely that the majority people who want to work in Coventry will be able to afford to buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
3. 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 already 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 closer to Coventry with a lower Green Belt value that should be used in preference to the land north of Milverton.
4. Myself, my family and my friends make extensive use of the footpaths and green belt land in this area on a nearly daily basis. It is clear that a valuable local asset will be lost, and the picturesque northern approaches to Leamington will be destroyed. This will significantly impact the quality of life for residents and make Leamington a much less desirable area to live in. All residents 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. Effectively the "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles, further devaluing the character of the area and merging the two towns.
In addition, the proposed park-and-ride scheme is unsustainable. This is because:
* There will be no dedicated buses, so users will have to time visits to coincide with the existing bus route timetable. As the new residents will not want to use the park and ride, congestion along the Kenilworth road at weekends will reach the point that people will be discouraged from shopping in Leamington.
* Shoppers are therefore unlikely to use the park and ride when there is plenty of parking in Leamington. I never fail to get a parking space in Leamington, even at busy times.
* 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. 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.
On this basis I believe that the land north of Milverton should remain in the Green Belt. The development proposed 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 a location more convenient to the intended residents. This approach would have the benefit of significantly reducing both costs and disruption for existing residents.

The NPPF, 2012, specifies: "... Green Belt boundaries should only be altered in exceptional circumstances". WDC has not demonstrated exceptional circumstances. The rationale, based on Coventry's housing need, is not realistic or sustainable, as people in Coventry will not want to buy homes and commute from North Milverton. There are more sustainable site options closer to Coventry. It would add to congestion and require new transport infrastructure. Valuable farmland, wildlife habitats, and highly valued recreational space for local people would be lost. Park and Ride and railway station are unsustainable and unviable.

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

This land represents a green space which improves the quality of life of walkers, cyclists and runners from all around the town.

The land designated to be removed from the green belt would be of no effective use to meet the stated housing needs of Coventry. It is not on an adequate access route; it is too far to be appealing to people working in Coventry; and it would increase road traffic in ways which are inconsistent with the 'green' aspirations of both towns.

There are green belt sites already designated of lower value than this area, which could be developed instead.

Given the parking along Rugby Rd, the junction of Old Milverton Rd & Rugby Rd would not be able to cope with the increased traffic if the proposed housing development takes place. It can currently take 45 minutes to drive from Milverton to the other side of Warwick. A new road would be needed from Old Milverton to Saxon Mill & the A429. I don't think that would be acceptable.

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

Government policy dictates that green belt boundaries can only be altered in exceptional circumstances.The proposed H50 area is all green belt and the modifications do not suggest any exceptional circumstances which justify changing this land's status.
Building on this land will increase the risk of flooding in the village again and will be exacerbated by the loss of trees when Cubbington Woods is decimated by HS2.
The proposed H50 development will have a devastating effect on the landscape of east Cubbington which will already be blighted by the construction of HS2.
The B4453 and surrounding roads are already busy at peak times - extra houses will lead to more cars and this coupled with the construction traffic required for HS2 can only lead to potential traffic hazards.
There seems to be no provision to accommodate the increase in demand for schooling and health needs, both of which are already fully subscribed.

Exceptional circumstances to remove the land north of Milverton from the green belt have not been demonstrated.
There are many other sites nearer to Coventry which could be used for Coventry's housing need. People who live and work in Coventry will not want to buy new expensive houses in Leamington.
The area of green belt in question has a high 'green belt value'. It's loss would have a detrimental effect on local residents.
Farm land & wildlife habitat would be lost.
For many reasons, the park & ride scheme will not work.

Exceptional circumstances to remove the land north of Milverton from the green belt have not been demonstrated.
There are many other sites nearer to Coventry which could be used for Coventry's housing need. People who live and work in Coventry will not want to buy new expensive houses in Leamington.
The area of green belt in question has a high 'green belt value'. It's loss would have a detrimental effect on local residents.
Farm land & wildlife habitat would be lost.
For many reasons, the park & ride scheme will not work.

Green Belt land N Milverton
I object because:
1.The Exceptional Circumstances required by the NPP Framework to justify removal of greenbelt land have not been shown. There are other , better and nearer sites to support Coventry's housing needs. These have been identified by WDC and Coventry CC.
The justification for releasing land from the Green Belt requires that those sites with the least Green Belt value be removed first. The Green Belt land at Milverton should be one of the last on the list.
2. If the houses are for Coventry's needs then they are in the wrong place, leading to more traffic congestion in traveling to Coventry.

3. The proposed railway station will not work as there is a deep cutting where it is proposed.
4. The proposals include some light industry. It is a good idea for people to live near their work. But how is light industry, which is in the plan, going to address Coventry's housing needs?
5. The area is much used by walkers and we see it well used. The prime farmland is an important resource as are the wildlife habitats.

6. The green space between Leamington and Warwick will be further reduced . This goes against the reasons for the Green Belt

This land is a much-used green space which improves the quality of life of walkers, cyclists and runners from all around the town.

The land designated to be removed from the green belt would be of no effective use to meet the stated housing needs of Coventry. It is not on an adequate access route. It is also too far away from Coventry to be appealing to people working there. And it would substantially increase road traffic.

There are green belt sites already designated of lower value than this area, which could be developed instead.

Re H44
Plan unsound because land affected North of Milverton is designated Green Belt and can only be allocated for development under Exceptional Circumstances which have not been proven.

Highly productive farmland will be lost, with long established wildlife habitats.

The Green Belt area makes as strong contribution to health and wellbeing , being available for sports and recreational pastimes.

The proposed development is intended for commuting to Coventry;the commuter routes are already congested at peak times. Add another 1000 cars? Chaos will ensue.
All unnecessary commuting is damaging to the environment.

This scheme is part of the 6,000 houses needed to meet Coventry City Council's housing needs. Surely it does not make sense to identify an area which is nearly 10 miles from Coventry when there are other sites which are much closer to Coventry and more suitable for this city's requirements? Otherwise, you are encouraging more people to commute between Leamington and Coventry;
* The proposed location is on Green Belt land immediately adjacent to the main road that links Leamington to Kenilworth and the busy A46 by-pass. Why build on land that provides a natural barrier between Leamington and Kenilworth when alternatives are available that would not do this?
* The location is not just Green Belt but prime Green Belt land. Why build on such valuable Green Belt land when lower value Green Belt land is available on the edge of Coventry which would better meet Coventry's housing needs?
* The land in question is currently used for productive farming. Why lose a productive farming area when there is less productive land available closer to Coventry?
* For many decades, residents in North-West Leamington have been able to walk to the bottom of Guy's Cliffe Avenue and out on to the fields where they can turn left to Old Milverton or right to Northumberland Road. These public footpaths are not ones that are used occasionally by weekend ramblers. They are used daily by dog walkers, runners, ordinary walkers and others. Why choose a location which has busy footpaths when there are alternative locations which have no public footpaths or footpaths which are only used occasionally?
* There will need to be access to this plot of land. It is difficult to see how there is enough space to create an entrance on to Northumberland Road which is already congested. The Kenilworth Road is the main road between Leamington and Kenilworth and it is illogical to create a new entrance on such a busy main road. Therefore, access would need to be via Old Milverton Lane. Whilst the roundabout on the Kenilworth Road could probably handle the additional traffic, many people who want to travel in the direction of Warwick will be tempted to turn left through Old Milverton. The only exit point is at the junction of Old Milverton Road and Rugby Road. That is already a busy junction. Realistically, how could it cope with all the additional traffic?
* The proposed park and ride scheme makes little sense. It is too close to Leamington and, assuming it is needed in the first place, it should be located closer to Kenilworth and the busy A46. However, why is it needed in this location in the first place? There is plenty of parking in Leamington itself. In addition, potential users will have no dedicated buses which means they will have to time their visits with whatever the bus timetable is;
* A new railway station at Old Milverton is included within this proposal. Has anyone actually visited the area in question? There is a very deep cutting in Old Milverton which surely means that the construction of such a railway station is simply not feasible?

This scheme is part of the 6,000 houses needed to meet Coventry City Council's housing needs. Surely it does not make sense to identify an area which is nearly 10 miles from Coventry when there are other sites which are much closer to Coventry and more suitable for this city's requirements? Otherwise, you are encouraging more people to commute between Leamington and Coventry;
* The proposed location is on Green Belt land immediately adjacent to the main road that links Leamington to Kenilworth and the busy A46 by-pass. Why build on land that provides a natural barrier between Leamington and Kenilworth when alternatives are available that would not do this?
* The location is not just Green Belt but prime Green Belt land. Why build on such valuable Green Belt land when lower value Green Belt land is available on the edge of Coventry which would better meet Coventry's housing needs?
* The land in question is currently used for productive farming. Why lose a productive farming area when there is less productive land available closer to Coventry?
* For many decades, residents in North-West Leamington have been able to walk to the bottom of Guy's Cliffe Avenue and out on to the fields where they can turn left to Old Milverton or right to Northumberland Road. These public footpaths are not ones that are used occasionally by weekend ramblers. They are used daily by dog walkers, runners, ordinary walkers and others. Why choose a location which has busy footpaths when there are alternative locations which have no public footpaths or footpaths which are only used occasionally?
* There will need to be access to this plot of land. It is difficult to see how there is enough space to create an entrance on to Northumberland Road which is already congested. The Kenilworth Road is the main road between Leamington and Kenilworth and it is illogical to create a new entrance on such a busy main road. Therefore, access would need to be via Old Milverton Lane. Whilst the roundabout on the Kenilworth Road could probably handle the additional traffic, many people who want to travel in the direction of Warwick will be tempted to turn left through Old Milverton. The only exit point is at the junction of Old Milverton Road and Rugby Road. That is already a busy junction. Realistically, how could it cope with all the additional traffic?
* The proposed park and ride scheme makes little sense. It is too close to Leamington and, assuming it is needed in the first place, it should be located closer to Kenilworth and the busy A46. However, why is it needed in this location in the first place? There is plenty of parking in Leamington itself. In addition, potential users will have no dedicated buses which means they will have to time their visits with whatever the bus timetable is;
* A new railway station at Old Milverton is included within this proposal. Has anyone actually visited the area in question? There is a very deep cutting in Old Milverton which surely means that the construction of such a railway station is simply not feasible?

Great Britain is a country which already needs to import a large amount of food to provide for the population and the destruction of ANY productive agricultural land at this time seems to be totally irresponsible. This is especially so, since I believe that areas of brownfield land within and close to Coventry have not been sufficiently considered with regard to housing the population of the city.
I am very unclear as to the desire of Coventry City dwellers wishing to live in an area remote from the city. A move to Leamington will involve additional commuting time and distance on roads which are already subject to traffic congestion at peak times.
Any housing plan involving the construction of dwellings to the north of Milverton will, almost certainly, encourage further developments which could, ultimately, result in the absorbing of Leek Wooton and Hill Wooton into the Leamington boundary.
The proposal for a 'Park & Ride' area to be sited to the north of Leamington is not sensible for the reasons stated in the 'changes' section below.
I live in a property which occupies a site at the lowest point of Windermere Drive. I have a personal concern that, should the proposed developments be permitted, there is a real risk of flooding around my home. At times of heavy rainfall, the roadway of Windermere Drive almost becomes a stream of water from the Borrowdale Road end and in front of my property. Even at times of moderate rainfall, a large pool of water collects in Widermere Drive, to the rear of No.1 Mosspaul Close. My concern is that, if the development goes ahead, it will remove the important 'soak away' element of the land involved and lead to a much heavier flow of water to the low point of Windermere Drive, resulting in a flood risk.

The development plans for houses on green belt land do not meet the exceptional circumstances test required by the National Planning Framework. The fundamental character and amenity of the three historic towns, Leamington Spa, Warwick and Kenilworth is to be destroyed because of a need to meet an unproven overspill need from Coventry.
There are many brown and green field sites in and around Coventry that would be better suited to meeting Coventry's housing needs without releasing local green belt and adding to traffic congestion. Such development would improve the prospects for Coventry's retail businesses, improve the current poor housing stock in Coventry and reduce the need for commuting on the already congested local road network.
The proposal to develop a park and ride facility North of Milverton seems perverse. Such schemes have a poor record nationally and usually only get used if parking in the Town/City served is either limited or highly priced. The alternative sites under consideration include much needed farmland, sloping ground and areas that play an important part in the flood management of the River Avon. The lack of a dedicated bus service will be a further limitation on the success of the P&R scheme.

Whilst acknowledging the need for additional housing during the period 2014-2029 the proposed modifications in their current form, does not meet the Planning Inspectorates instruction regarding HMA cooperation 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 sustainable growth objectives and evidence base.

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.

Table 1: Potential additional housing availability in Coventry
Reference Hectares Housing potential (units)
Bab 2 9.38 247
Bab 8, 33 10.39 228




Bab 16 47.23 800
Bab 19 19.57 430
Bab 29
8.26
198

Bab 51a
10.0 225
Bab 51b 9.6 230
Bab 54 4.46 107
Bab 57 12.96 330
Bab 67 5.06 129
Bab 68 21.58 491
Bab 70 18.7 2250
Bab 29
8.26 198
BW 38 4.5 108
F54 18.25 450
H 8a and b 4.15 150
HE 14a, b, c 6 900
Ho10 30.1 790
Bab 29
8.26 198
L30 8.6 206
S4 2.96 110
S5 2.19 100
STM 27 1.56 300
STM 61 0.75 143
STM 64 1.99 440
STM 65 0.79 150
STM 41 0.75 143
WE 28 11.59 230
STM 41 0.75 143
TOTAL 10,424

Objection 4. The Joint memorandum of addressing unmet housing need of 14,000 homes in Coventry is unsound.
Coventry City Council's aspiration to improve the provision of the right quality housing to meet the needs of Coventry City's population (Local Plan Policy H1,H2, H3) and sustainable development (Policy DS3) would be better served by taking into account available low grade Green Belt and Green Field land shown in
table 1 and reducing the burden on inappropriate development in more distant neighbouring areas. Doing so would sustain the functional link between housing and work thereby contributing to the wider aspirations of health and well-being of the population detailed in the Coventry's Local Plan.

Objection 5. Proposed building of houses in Leamington to meet the needs of Coventry people does not meet National Planning Policy Framework Guidance note 49
Whilst accepting the need to cooperate to meet unfulfilled housing need in the wider housing Market area, (modification 2, 15 Para 2.6) proposals must also comply with NPPF. The proposal to build at Milverton does not stand up to the test of presumption of sustainable development particularly when other more suitable sites exists. (See table 1).


Objection 6 Enroachment/Coalescence of Leamington Spa and Old Milverton
The development of East Milverton does not comply with National Planning Policy Framework March 2012 guideline chapter 9, Paragraph 85, point 6 and Planning Practise Guidance Section 9 note 80 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. This view is upheld by the Joint Green Belt Study January 2016 which states:

The parcel RL1 prevents Leamington Spa adjacent to the southern edge of the parcel from merging with the small village of Old Milverton adjacent to the western edge of the parcel on the other side of the railway line which runs along this edge of the parcel. Although the railway line plays a separating role development along the eastern side of the line up to Sandy Lane would effectively merge these two settlements.


Objection 7 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.

Other opportunities to meet HMA requirement
In the event that Green Field/Green Belt land should be required, then the 269.2 hectares of land at Kings Hill Lane (Warwick District Council SHLAA Ref C06 should be planned to best meet the needs of Coventry's housing. This approach combined with Green Belt land identified in the Coventry SHLAA offers a more sustainable approach to meeting housing need and protects valuable agricultural land without the requirement for expensive and unsound transport infrastructure projects.

Hopefully from the objections and suggestions I have made, coupled with a further review of the WDC, Coventry City Council HMA and Joint Green Belt Study evidence base, you will recognise that there is no justification for developing Milverton and should flexibility in the plan be required, other more suitable sites for development exist within the District.

Mod 16 Objections
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 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 Exceptional circumstances required by the National Planning Framework to remove the land north of Milverton from the green belt have not been demonstrated by WDC.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be use in preference to the land north of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practise it is likely that people who want to live and work in Coventry will not want to buy houses in Leamington and therefore this proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the value of potential sites 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. 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 Leamington Spa will be destroyed.
Highly productive farming land will be lost, together with long-established wildlife habitat.
Leamington and other local residents will be deprived of an area which is highly valued and sustainable for walking, running, bird-watching and also used by local schools for educational walks.
The proposed park and ride scheme is unsustainable because:
* There will be no dedicated buses
* The site is too close to Leamington to encourage people to use it
* There is already plenty of parking in Leamington for shoppers and therefore they are unlikely to use it. As a past resident of Oxford, this is the only scheme I am aware of that works, because there is very limited parking in Oxford and what parking exists is very expensive. In addition, dedicated buses run every few minutes.
* There are already a lot of car parks in this area of the green belt with impervious surfaces, which reduce the ability to absorb rainfall and therefore contribute to flooding.
A railway station is unviable because the railway line is 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 greenbelt have not been demonstrated by Warwick District Council.

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

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

Precedence for releasing land from the green belt required the "value" of potential sites to the green belt to be taken into account and those with the least value to be removed 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 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 wildlife 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 secondary schools for educational walks.

The proposed park and ride scheme is unsustainable because:
- there will be no dedicated buses, so users will have to coincide visits 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 major employers.
- Shoppers are unlikely to use the park and ride where 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 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 on Old Milverton making construction impractical.

The Council needs to recognise that their are NO actual Exceptional Circumstances to develop the Green Belt to the North of Leamington and that as a consequence the proposal to develop in Old Milverton should be thrown out. Recognition that the greenbelt is there to prevent urban sprawl is vital to preserve the limited green space between Leamington and Kenilworth, otherwise there is a real risk that Leamington and Warwick will merge with the West Midlands conurbation. Green belt should not re allocated for any reason, that is what it is there for after all.

Also in the Prime Minister speech on xxx in March 2015 he stated & I quote "The line remains scored in the sand - that land is precious. I am a country man. I love our countryside.

"For years Labour's failed regional strategies cast a shadow over our fields and forests threatening to carve them up and cover them in ugliness.

We've taken a totally different approach and protecting the Green Belt is paramount....

Put simply: the Green Belt is protected with us. And it is not just green belt that concerns people but green fields."

EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove land from the Green Belt have not been demonstrated.
The development is to support Coventry's housing needs. There are sustainable sites closer to Coventry.
Development will not support Coventry's housing need.
Sites on the edge of Coventry are of lower Green Belt value.
The "green lung" between Leamington and Kenilworth will be reduced unacceptably.
Highly productive farming land will be lost together with long established wild life habitat.
The area is highly valued and sustainable for multiple activities, including being used by local schools for educational purposes.

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 andtherefore 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 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

EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove land from the Green Belt have not been demonstrated.
The development is to support Coventry's housing needs. There are sustainable sites closer to Coventry.
Development will not support Coventry's housing need.
Sites on the edge of Coventry are of lower Green Belt value.
The "green lung" between Leamington and Kenilworth will be reduced unacceptably.
Highly productive farming land will be lost together with long established wild life habitat.
The area is highly valued and sustainable for multiple activities, including being used by local schools for educational purposes.

EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove land from the Green Belt have not been demonstrated.
The development is to support Coventry's housing needs. There are sustainable sites closer to Coventry.
Development will not support Coventry's housing need.
Sites on the edge of Coventry are of lower Green Belt value.
The "green lung" between Leamington and Kenilworth will be reduced unacceptably.
Highly productive farming land will be lost together with long established wild life habitat.
The area is highly valued and sustainable for multiple activities, including being used by local schools for educational purposes.

EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove land from the Green Belt have not been demonstrated.
The development is to support Coventry's housing needs. There are sustainable sites closer to Coventry.
Development will not support Coventry's housing need.
Sites on the edge of Coventry are of lower Green Belt value.
The "green lung" between Leamington and Kenilworth will be reduced unacceptably.
Highly productive farming land will be lost together with long established wild life habitat.
The area is highly valued and sustainable for multiple activities, including being used by local schools for educational purposes.

I am writing to object to removing the land North of Milverton from the Green Belt. Warwick DC has not demonstrated that sites with lower value cannot be removed from Green Belt first. This application supports the housing needs of Coventry. Itis unlikely that people who want to live and work in Coventry will buy houses on the land North of Milverton and therefore this development proposal will not support Coventry's housing needs. Furthermore, there are sites closer to Coventry with a lower Green Belt value that should be used in preference to the land at Milverton.

Please see attached letter of objection