Mod 16 - para 2.81

Please see attached letter of objection

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.

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.

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.

Development in the green belt to the north of Leamington does not comply with the National Planning Policy Framework, is not sustainable, is not close to employment opportunities, and is, therefore, inappropriate. The notion of spreading development across the District is ill conceived since development should be sustainable and close to employment. Warwick District Council has consistently failed to demonstrate the Exceptional Circumstances required by the National Planning Policy Framework to allow substantial development in the Green Belt to the north of Leamington.
In the most recent draft of the Local Plan it is proposed to build 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. Warwick District Council has stated that it wants to remove this land from the Green Belt 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 there are no exceptional circumstances to remove it from the green belt. There are other more appropriate and sustainable sites outside the green belt. Similarly, 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 don't work unless there is insufficient parking available in the 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

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

The ecceptional 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. Sustainable sites closer to Coventry should be used in preference to the land North of Milverton as residents of Coventry should not be required to relocate this far afield. Coventry has provided large quantities of student accommodation at the expense of its local residents.
Removing this Green Belt land will destroy much needed farming land, walking, cycling and many more outdoor opportunities for leisure. If this Green Belt is taken away from Leamington residents how far will they have to go to get out of urbanisation? More houses means more cars, more energy requirement, more carbon emissions. Green Belt preserves the environment.

The exceptional circumstances required by the National Planning Policy Framework have not been demonstrated by Warwick District Council for the removal of land North of Milverton from the Green Belt.
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.
Precedents for releasing land from the Green Belt require the 'value' to the Green Belt of potential sites to be taken into account, and those with 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 were 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 approach to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farm 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, and bird watching, and is also used by local schools for educational walks.

Park and ride scheme
The land is highly valued by the town as an area for recreational activities as well as used by local schools for educational walks.

I believe 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
As there is already plenty of parking in Leamington shoppers with the major employers in the South of the borough the site will be unused.
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.
With the site being unused it would be abused and seen as an opportunity to be used as an illegal caravan park as the cark park at Newbold Comyn.
A railway station is unviable because the railway line is in a 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. These circumstances have not been demonstrated by Warwick District Council.
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.

This is a war on the countryside. As far as I know the Green Belt protections remain in place and all new settlements should be locally led and not imposed on communities.
The picturesque northern gateway to Royal Leamington Spa will be destroyed if this plan goes ahead and the Green Lung between Kenilworth and Leamington Spa will be reduced to less than 1 1/2 miles. The highly productive, high value farming land with long established wild life habitat will be destroyed. The local residents will be deprived of an area which is enjoyed for walking, running, cycling and riding.
The idea that tiny Milverton should provide houses for Coventry City Council is wrong. We the residents were not consulted. Coventry is a huge city and must find its own land and not ours to build their houses on. Anyway it is illogical and not green planning for Coventry workers to live in Leamington and to commute to Coventry every day. If each household has two cars imagine what a lot of extra cars and fumes will be on our roads.
Land must be found nearer Coventry, whether north,south, east or west. In fact land is available at Kings Hill.
There are no exceptional circumstances to remove this land from the Green Belt. There are other sites adjacent to Coventry with a lower Green Belt value that should be used in preference to the land north of 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 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.

I believe the plan to remove the land North of Milverton from the Green Belt are unsound. Warwick District Council have not demonstrated the Exceptional Circumstances required by the National Planning Policy Framework.
Given that the development is to support the housing needs of Coventry City Council there are sustainable sites nearer to Coventry that should be used so as to reduce extra commuting and the inevitable congestion and road construction that would be required.
People who live and work in Coventry will want to buy houses in Coventry rather than on land North of Milverton.
I understand that the 'value' of potential sites to the Green Belt has been taken into account when releasing land from the Green Belt - those with the least value should be removed first. I understand that Warwick District Council and Coventry City Council have identified sites on the edge of Coventry as being of lower Green Belt value. Those sites should be used in preference to the higher value Green Belt land North of Milverton.
I am concerned that the green space between Leamington and Kenilworth will be reduced - to less than 1.5 miles - and that the beautiful northern entry to the historic town of Royal Leamington Spa will be destroyed forever.
The farmland and natural wildlife habitat that currently exists North of Milverton will also be lost forever.
And of course, residents of local towns will lose their highly popular leisure area in which there are always walkers, runners, cyclists and nature lovers. The local schools will lose an easily accessible source of educational opportunities.

* The EXCEPTIONAL CIRCUMSTANCES required to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
*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.
*There are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
* Prime farm land will be lost with ecological damage.
* The green lung between Leamington and Kenilworth will be less than 1.5 miles.

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.

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.

Warwick District Council is exceeding its legal authority by fulfilling another area's housing needs instead of representing those who live in the area. This is unlawful and could be struck down by judicial review. Moreover, it is unlawful for Warwick District council to use its resources to fight such a case on behalf of another authority.

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 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

The National Planning Policy framework requires the citing of exceptional circumstances to remove land from the Green Belt - no such circumstances have been identified.
The land that has been proposed in North Leamington is highly productive farming land. It has been designated as having high grade value.
There are no other replacement sites where such high yield could be generated, there are plenty of other sites where houses can be built.
As a country we need to be able to grow food.

This modification proposes removing well used recreational land as a time when:
the 2014/15 HSE report recorded 9.9 millions days were lost through stress related illness (1); the British Heart Foundation reports the economic burden of cardiovascular disease to be £15 billion per year, with one person dying every 3 minutes (2); Diabetes UK records a cost of £10 billion per year with 100 amputation per week (3); Public Health England report obesity direct costs as £4.2 billion with an estimated indirect cost of £15.8 billion.
It has been demonstrated that quality space is needed for people to exercise, relax and enjoy the countryside as part of their health regime

Warwick District Council and Coventry City Council have assessed sites on the edge of Coventry and deemed them to be of lower Green Belt value than this land to the north of Milverton. Precedence for releasing Green Belt land requires that the sites with least value should be removed first.
There has been no thorough study which demonstrates a sequential approach to the surrounding land to identify land which fits with the spatial strategy (5)

Brandon Lewis, minister for Housing and Planning stated in Parliament on 15 March 2016 'National policy sets out that planning must take account of the different roles and characters of different areas, recognise the intrinsic character and beauty of the countryside, and take into account all the benefits that an area has.' (6)


For the above reasons I consider that the plan does not meet the national policy as so recently reinforced by the housing minister's statement.


(1)www.hse.gov.uk/statistics/causdis/stress
(2) www.bhf.org.uk/research/heart-statistics
(3) www.diabetes.org.uk
(4) www.noo.org.uk/NOO_about_obesity/economics
(5) Joint Core Strategy Inspector's Preliminary Findings on green belt release, paragraph 33
(6) hansard.digiminster.com/Commons/2016-03-15/debates/16031557000003

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

I have spent time reviewing the proposed Local Plan and do not think that the exceptional circumstances required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have been sufficiently demonstrated by Warwick District Council.

My particular concerns to this modification are as follows:

I would point to the 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. I understand that WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Therefore, 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 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. I would question whether people who want to live and work in Coventry would choose to buy houses on land North of Milverton, so I can not see how the development proposal will support Coventry's housing needs.
.

I would also highlight that the modification is unsound as it would result in "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

The environmental and social consequences of the modification would also be extremely damaging and irreversible. Not only would the area lose highly
productive farming land but also a fantastic recreational space. Like many other local residents, my family, including my two young children delight in walking, bird watching and enjoying the fresh air of this special area.
I believe the protection of the Green belt is extremely important and I would urge that this modification be reconsidered.

I have spent time reviewing the proposed Local Plan and do not think that the exceptional circumstances required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have been sufficiently demonstrated by Warwick District Council.

My particular concerns to this modification are as follows:

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. I would question whether people who want to live and work in Coventry would choose to buy houses on land North of Milverton, so I can not see how the development proposal will support Coventry's housing needs.

The 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. I understand that WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green
Belt value. Therefore, 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.

I would also highlight that the modification is unsound as it would result in "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

The environmental and social consequences of the modification would also be extremely damaging and irreversible. Not only would the area lose highly
productive farming land but also a fantastic recreational space. Like many other local residents, my family, including my two young children enjoy walking, bird watching and enjoying the fresh air of this special area.

It is also used by people who may not live in the area, but park cars by the fields to take advantage of the countryside to jog and walk dogs - it is an area that is well known among people who work in Warwick as a beautiful walk linking the Saxon Mill, Milverton and Leamington - to lose such a unique terrain when other areas could be used which are more suitable for Coventry's housing needs would be a short-sighted mistake.

I believe the protection of the Green belt is extremely important and I would urge that this modification be reconsidered

Additionally, the proposed infrastructure developments for public transport seem vague and dependent on other stakeholders cooperation and requiring huge investment that could result in an unsustainable (environmentally and financially) white elephants.

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

A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical. With the single track, the model so successfully demonstrated by Chiltern Railways on the Warwick Parkway development, would not be feasible or financially attractive to an investing train company.

the plan does not take into account numerous lower green belt value land closer and within Coventry boundaries . the plan is unsound as more pollution will be generated from commuting.

Peak traffic is almost already at a standstill, this proposal does not take this into account

Th area is productive farmland , I suggest looking at developing the huge areas of brown field sites in the area before cutting huge areas of green belt land.

Th green belt was put in place to prevent developments such as the one proposed

The argument that housing should be provided at Old Milverton to support Coventry's need is flawed: -

- The exceptional circumstances for removing land from the greenbelt have not been adequately demonstrated
- Sites on the outskirts of Coventry have been assessed to be of lower greenbelt value and precedence should be given to releasing these if any greenbelt land needs to be released. This should only be done if all brownfield sites have been exhausted within the city boundaries
- Kenilworth, Leamington Spa & Warwick are three distinct towns with unique characteristics, attracting a diverse cross section of society. These residents can mutually enjoy the greenbelt in between their towns providing a unique recreational opportunity on the doorstep of all 3 towns. A society seeking to encourage a healthy lifestyle must respect & maintain natural recreational areas

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

Precedence for releasing land from the Green Belt requires the "value" of the 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 the proposed 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.

Highly productive farming land will be lost all together with long established wildlife.

The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, 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