Mod 23 - Paras New2.1 to New2.3

In my opinion 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 removal of land North of Milverton from the green belt is intended to support Coventry City Council'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. Warwick District Council, in cooperation with Coventry City Council, has assessed available sites on the edge of Coventry as being of lower Green Belt value than the green belt land North of Milverton and these should be used in preference to the land North of Milverton.

Using sites closer to Coventry to address the housing needs for Coventry makes obvious sense as it minimises unnecessary commuting, inevitable congestion and further road construction and enables people who wish to live and work in Coventry to do so.

The principles of the policy are accepted as safeguarding land for future development is sound. Whilst land at Cryfield Grange / South of Gibbet Hill Road (referred to in the Representation on Modification 22) is considered to be suitable for allocation now, if this is not deemed appropriate, than it is considered that it should be identified as Safeguarded Land.
It directly adjoins: existing development; the University development; proposed development land in Coventry; and, other than Green Belt, is not affected by any suitability criteria used to define future development land.

It was with dismay that I read in the Courier that the council is again targeting Green Belt land North of Leamington for development, it felt worse that it seems that it is being used as a Coventry overspill.
Is Bill Gifford the only councillor that can see the obvious fact that a Coventry overspill should be sited by Coventry?
If the proposed park and ride in Blackdown proves to be a failure, is there provision to return the land to Green Belt and ensure there is no development on this land?
Old Milverton and Blackdown parish council were excellent last time the council tried to use this precious Green Belt which keeps our local identity separate from Kenilworth and as a proud Leamingtonian, I will fully support them in their efforts to have this attempt refused.

In June 2012 I wrote to the Council objecting strongly to the plans to build on green belt land north of Leamington.

At the time, the plan was based on population growth forecasts which, in my view were erroneous and it did not follow the NPPF.

Nothing has changed, so why has this plan been put forward again?

The NPPF states that any plan should:

1 Promote town centre environments
2 Promote vitality of urban areas
3 Protect green belts around them
4 Recognise the benefits of best agricultural land
5 Conserve landscape and scenic beauty
6 Use brown field sites first
7 Only change green belt boundaries under exceptional circumstances
8 Even then only consider limited infilling of green belt land
9 Avoid potential coalescence

These plans ignore all 9 points.

These are not exceptional circumstances.

The plans should be scrapped again to preserve the sacrosanct boundaries in this 'Green and Pleasant Land'.

I am writing to register my vehement opposition to Warwick District Council's proposed removal of the land north of Milverton from the green belt and development plans in the immediate area as sited in modifications 14 and 16(Policy DS15). As a long standing resident and tax payer of North Leamington I am proud to have such a special area of protected land in the green belt area around Milverton and Old Milverton and as a member of the congregation of St.James church in Old Milverton I find the peace and serenity to worship in such a setting a true blessing. As a keen nature lover I regularly frequent the village and surrounding fields in my free time for walking,bird watching and enjoying the beauty held there as I know many other individuals,families and school groups alike do. The land is also a site of highly productive farming and a long established wildlife habitat which we should all fight to preserve. Development would forever spoiling village life for those who have long lived and visited there . I do not believe that developing this land to produce housing would prove desirable or practical to provide the housing needs of those who want to live and work in Coventry and,if developed,the damage to this beauty and habitat would be irrevocable. I do not believe that the 'exceptional circumstances' required to remove the land north of Milverton from the Green Belt has been demonstrated by Warwick District Council and I feel that other sites assessed by WDC and Coventry City Council of a lower Green Belt value on the edge of Coventry would be not only wiser in terms of the lesser environmental and recreational value but also more practical in their proximity to Coventry,reducing the need for unnecessary commuting,inevitable congestion of an already heavily travelled route . Surely those sites with a lower Green Belt value should be used in preference to that North of Milverton! The green lung between Leamington and Kenilworth would be reduced to 1 1/2 miles were development be allowed and the picturesque northern gateway to regency Leamington Spa would be lost to urban sprawl.
In regards to the proposed park and ride scheme I believe that this would be unsustainable as there are no dedicated buses planned so users would have to time visits to coincide with the bus timetable,something which regular commuters would be less likely to do than casual visitors and the site planned is too close to Leamington and would create further gridlock near the town. It would be better sited near 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. I also believe that shoppers are unlikely to use the park and ride scheme when there is plenty of existing parking in and around Leamington. Furthermore,there are already numerous car parks in the proposed area of Green Belt with impervious surfaces,all of which reduce the area's ability to absorb rainfall and contribute to flooding,something which is already a regular occurrence in heavy rainfall.
I cannot convey strongly enough my opposition to the proposed plans,both on a practical and emotional basis and hope that Warwick District Council will heed the views of its residents before making the mistake of causing irrevocable change and damage. Thank you for your consideration of my views.

Modification: Removal of land north of Milverton from the green belt
Mod Number: 16
Paragraph Number: 2.81
Mod. Policies Map Number: H44

Modification: Allocation of land north of Milverton for development
Mod Number: 14
Paragraph Number: Policy DS15
Mod. Policies Map Number: H44

In my opinion the Local Plan is unsound because it is not justified, effective nor is it consistent with National policy.

Warwick District Council ("WDC") has failed to demonstrate 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.

Initially 250 houses are proposed to support Coventry City Council's housing need. In practice people who want to live and work in Coventry will not buy houses on land North of Milverton and, therefore, this development will not support Coventry's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton so as to reduce unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable. In addition this is a very small development, which equates to an annual additional build of only 19.2 houses over the remaining 13 years of the Plan period. These houses could be accommodated on other sites and, 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.

Additional land north of Milverton is to be "safeguarded" for development beyond the Plan period, to provide a further 1100 homes for Coventry. This will not support Coventry's hosing need because in practice people who want to live and work in Coventry will not buy houses on land North of Milverton. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to prevent unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable.

WDC has also said that the "safeguarded land" north of Milverton could be used in the future to support Leamington's housing need. There are other green field sites that are available, and deliverable which should be used in preference. Therefore, WDC 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. Nothing has changed which could alter this acceptance.

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.

The land North of Milverton is used by many people for recreation. If developed 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 land North of Milverton has performed the requirements of the Green Belt and it should continue to do so:

* It has stopped Kenilworth, Coventry and Leamington merging. If this land is removed from the green belt the "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

* It has stopped Leamington "sprawling". Development stops at the green belt boundary

* It protects the historic setting for regency town of Royal Leamington Spa which will be destroyed if development is allowed.

* It has encouraged urban regeneration in the neighbouring towns

* It has safeguarded the countryside. If this land is removed from the green belt, highly productive farming land will be lost together with long established wild life habitat.

In order for the modifications to the Local Plan to become sound the land North of Milverton should remain in the Green Belt.

In total Warwick District Council has agreed to provide land for 6000 houses to meet Coventry's housing need. However the modifications to the Local Plan 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.

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