H44 - North of Milverton

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
Modification: No 14-
Para: Policy DS15
Mod. Policies Map Number: H44

I have read the proposals in the WDC Draft Local Plan and would like to express my concerns and objections.


I would like to register a formal objection to the removal of land from the Green Belt north of Milverton, and the proposed building of 250 houses and park-and-ride scheme, followed by a further 1100 houses, railway station and commercial property within 5 years.

I believe that we must provide additional housing in South Warwickshire, but It is preposterous that this green belt land should be used to support Coventry City's housing need, and I cannot believe that this is sustainable.

Traffic congestion in the Leamington/Warwick area is already an enormous problem and whilst the suggestion of Park and Ride facilities are put forward I do not believe that residents of the proposed area will want to use the facility to travel into Coventry, and will certainly not use it for trips into Leamington Spa. They will use their cars.

The "Exceptional Circumstances" needed to remove this land from the green belt do not exist. There are lesser value sites closer to Coventry which on the basis of planning precedent should be used in preference to the land in Old Milverton. It is very far fetched to suggest that people living and working in Coventry will be interested in buying houses and living in Old Milverton.

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
Modification: No 14-
Para: Policy DS15
Mod. Policies Map Number: H44

I have read the proposals in the WDC Draft Local Plan and would like to express my concerns and objections.


I would like to register a formal objection to the removal of land from the Green Belt north of Milverton, and the proposed building of 250 houses and park-and-ride scheme, followed by a further 1100 houses, railway station and commercial property within 5 years.

Whilst there may be need to provide additional housing in South Warwickshire in the future, it is not logical nor permissible to consider using this green belt land to support Coventry City's housing need. This proposal does not demonstrate removal of Green Belt Land in and around Old Milverton is a viable solution for that purpose nor does it have any merit in demonstrating Coventry folk both living and working in the City would contemplate buying houses in Old Milverton.

Traffic congestion in the Leamington/Warwick area is already a significant problem on both Southern and Northern entry/exit routes and whilst the suggestion of Park and Ride facilities are put forward it has not been demonstrated that residents of the proposed area will want to use the facility to travel into Coventry, and will certainly not use it for trips into Leamington Spa. They will use their cars.

The proposal for an additional railway station in the Milverton area again has no logic considering the existence of existing under-utilised facilities in inter alia, Leamington Spa, Warwick, Warwick Parkway and the Kenilworth facility under construction..

The "Exceptional Circumstances" needed to be demonstrated to allow a decision to remove this land from the green belt have not been demonstrated and do not, to my sight exist. To my understanding there are lesser value sites closer to Coventry which, on the basis of planning precedent, should be used in preference to the land in Old Milverton.

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.

I should like to request that this proposed development be reviewed with a view to finding an alternative site for Coventry overspill housing.
I do not live in this part of Leamington Spa but nonetheless appreciate the "Green Lung" between Leamington and Kenilworth and consider it important to maintain for the well-being of urban dwellers. The green fields and countryside, the allotments and village communities around the town contribute to the quality of life of its inhabitants. The countryside is also an important natural habitat for wild life. People like to and need to be able to go walking, dog walking, running, cycling and/or riding to relax in their free time - the environs of Leamington as they are still permit this - even without a car.
There is evidently a shortage of housing but for some twenty years we have mostly seen developments of luxury housing and buy-to-lets. This does not address the needs of most ordinary people. It may be that it is time to consider the development of a new town rather than endless brown fill and green site development projects. The density of the town's population and accompanying traffic pollution must be a consideration.
It is arguable that if this housing proposal is to alleviate the Coventry housing crisis, that it would be preferable to make the development nearer Coventry.
More houses around this part of Leamington will add volumes of traffic to an already busy commuter part of town.
Please think again.
Only the builders will benefit from this and they are rich enough.

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 have read the proposals in the WDC Draft Local Plan and would like to express my concerns and objections.

Whilst agreeing to the need for additional housing to be provided in Warwickshire I firmly object to the withdrawal of the green belt land to the north of Milverton to provide for this new housing.

The green belt is a very valuable green lung and provides an area of great benefit for the residents of Leamington Spa and Kenilworth healthy activities including walking, running, cycling of etc

It is important as a positive break between the two conurbations and as a necessary wild life habitat.

Whilst agreeing to the need for sustainable development I cannot agree that exceptional circumstances can be demonstrated for the land to be released for this proposed invasion of the green belt at this time.

There is a suggestion of the provision of a Park & Ride facility. To what benefit? I do not believe that residents of the suggested development will use this facility when it is so close to the centre of Leamington Spa. If they have cars they will always prefer using them unless they only have very lightweight shopping to carry. Also the existing roads into Leamington Spa and Warwick are already terribly congested, and even if they are widened there will still be bottleneck at the entrance and exit from the towns without the addition of a possible 1350 plus cars for the residents proposed over the next 5 years.

The proposed development in Old Milverton to provide housing for Coventry is absurd. This is not sustainable. It should be close to Coventry where there is plenty of available space, both to the North. South and West which have already been identified as of much lower green belt value. Coventry's need for additional housing should be met by development closer to Coventry to be more sustainable, and I do not believe that there are exceptional circumstances for removing the Green Belt land to the north of Milverton.

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.

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 co-operation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower green belt value. Even if development at old Milverton was acceptable as a sustainable location for development, there are sites with a lower green belt value that should be used in preference to the land north of Milverton.
The green lung between Leamington and Kenilworth will be reduced to less than 1.5 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established 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 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 focussed 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.

See attached

See attached

See attached

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.

1) 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.

2) 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.

3) 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.

4) Precedence for releasing land from the Green Belt requires the "value" of potential sites in the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in co-operation 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.

5) The rural gap between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

6) The attractive northern approach to Leamington Spa will be adversely affected.

7) Good farming land will be lost together with long established wild life habitat.

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



9) The proposed park-and-ride scheme is impractical because:-

a) There will be no dedicated buses, so users will have to time arrivals to coincide with the bus timetable.

b) 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.

c) Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers

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

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



As a solution the development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing in a more convenient location for the residents.

See attached

Even though it purports to follow government guidance, the Strategic Housing Market Assessment (SHMA) is not independent and is seriously defective. It has considered only one side of the equation and only those with a vested interest in growth have influenced its findings. Population and household projections have been wrongly used as if they were forecasts. The assumption on headship rates is questionable and the study fails to get to grips adequately with economic issues, commuting, international migration, student needs and affordable housing. Above all, the SHMA acknowledges the high degree of uncertainty about the future but then plumps for a single figure of so-called Objectively Assessed Need (OAN) which is poorly justified. This figure is seriously lacking in credibility. [section 3]

The local authorities in their Memorandum of Understanding have misused the SHMA by adopting the so-called OAN uncritically and indeed adding to it. They have failed to consider whether environmental and other policy factors limit the ability of the area to meet its housing needs. The decisions they have reached about the distribution of housing provision within the housing market area are arbitrary, opaque and extreme, making the proposed plan unsound and unsustainable. The proposal that Warwick District should take the largest share of Coventry's overspill is reckless and wholly unjustified given the Green Belt status of a large part of the district. [section 4]

The Council have failed to demonstrate that nearly 17,000 dwellings can be built in the district by 2029. All the evidence suggests otherwise. Their response to the low level of dwelling completions in the first four years of the plan period is to allocate even more housing, without considering what (if anything) can be done to improve building rates within the existing allocation. As a result, the proposed plan would have a range of undesirable consequences for urban regeneration, vacancy rates and dereliction, commuting, service and infrastructure costs, housing opportunities and loss of Green Belt which neither the Council nor the Sustainability Appraisal have adequately considered. Those negative effects which the Sustainability Appraisal does recognise have played no apparent part in the development of the strategy. Almost half the dwellings to be built on allocated sites are in the Green Belt. The proposed plan is unsustainable and is directly at odds with policy in the National Planning Policy Framework. [sections 5 and 6]

The proposed plan and the cumulative impact of its development proposals would exacerbate problems which the district already faces such as loss of character and environmental quality, traffic congestion and inadequate public transport. Many of the individual housing proposals - particularly those involving substantial loss of Green Belt - cannot be justified and will do great damage. Nearly half of housing development on allocated sites would be in the Green Belt and the proposed plan does not comply with government policy on housing development in the Green Belt. Insufficient consideration has been given to the infrastructure implications of development on such a large scale. [section 7]

The plan is unsound, unsustainable and unworkable. It stems from a deluded view of the growth potential of Coventry and Warwickshire and is contrary to government policy. The plan needs to be fundamentally re-thought and housing provision of between 10,000 and 10,500 dwellings would be much more appropriate and potentially achievable. [section 8]

3. Defects in the Strategic Housing Market Assessment (SHMA)
The SHMA prepared by G L Hearn was intended to be an objective assessment of housing need in Coventry and Warwickshire. While it purports to follow government guidance, it has the following serious defects which fatally undermine its credibility:
* As a general rule, only organisations with a vested interest in increasing housing provision from its already very high level have been consulted. Those able to take a more detached and balanced view were conspicuously excluded. The local authorities themselves have a strong incentive to push house building rates higher and higher thanks to the New Homes Bonus.
* While the terms of reference for the study are reasonably objective, a wealth of e-mail correspondence between the local authorities and the consultants (released under the Freedom of Information Act ) suggests that there was a good deal of manipulation behind the scenes.
* The study rightly uses ONS population and household projections as the baseline for its work, but treats them as if they were forecasts. On the contrary, ONS say ''The population projections have limitations. They are not forecasts (my italics) and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors (for example, government policies on immigration or student fees) might have on demographic behaviour...... As a forecast of the future population they would inevitably be proved wrong, to a greater or lesser extent..... Projections become increasingly uncertain the further they are carried forward into the future'. Hearns have fundamentally erred in treating the projections as forecasts and failing to consider how the policies or other factors that underlie them may change in future. They assume (paragraph 3.34) that uncertainty is mainly attributable to inadequacies in base data, but the effects of future changes in societal trends and public policy are likely to be far more influential. The SHMA never faces up to these issues.
* There is an unexplained anomaly in the use of the projections. The difference from the 2011-based to the 2012-based projections for the HMA is a decrease of 127 dwellings per annum. However, in Hearns' work this results in an increase of between 472 and 572 dwellings per annum . The consultants do not adequately explain this apparent conflict.
* The approach is based on the implicit assumption that new dwellings will meet existing and future housing needs, but this is not the case. Almost 90% of the private housing market involves existing, not new, housing stock. With the exception of starter homes, the great majority of new dwellings are bought by existing home owners. Except in the very long term, prices are insensitive to the volume of new house building and the market is not particularly effective in ensuring that newly arising housing needs are met.
* The study rightly explores a very wide range of scenarios in its attempts to quantify Objectively Assessed Need but fails to critique the underlying methodologies of the different models in which it places its faith. The study plumps for single figures within the range of possible outcomes (often towards the upper end of the range) that are arbitrary or poorly justified. The eventual recommendation that 4,272 dwellings per annum should be built in Coventry and Warwickshire seems to be a black-box generated number instead of being backed up by credible analysis at each step in the process.
* The 'part return to trend' on headship rates is poorly explained and justified. It is far from certain yet whether the cessation of the fall in average household size in recent years is just a 'blip' or the 'new normal' . The factors likely to influence this lead in different directions and give different outcomes. The consultants assume that a reduction in average household size will resume, but there is very little evidence for this;
* The economic forecasts used by Hearns give widely divergent results. The fact that they are based on past development trends is a major weakness, particularly as only a short, probably unrepresentative period has been considered. They also lack explicit assumptions about the productivity relationship between GVA and job growth. Yet the Local Enterprise Partnership is trying to attract high tech and high value added jobs, which would result in a lower number of jobs for a given level of GVA;
* The Strategic Employment Land Study is based on very arbitrary assumptions and data and has not been subjected to critical analysis. The 'talking up' of Coventry's employment prospects in section 4 of the study is very speculative, verging on wishful thinking, and the whole OAN is consistent with a rose-tinted view of economic prospects in Coventry and Warwickshire, bearing in mind past lower than national growth rates and skills shortages . Hearns have suggested upward adjustments to OAN in some areas in relation to economic prospects, but do not seem to have considered downward adjustments in other areas so the analysis is all one way. The equation made between jobs and people is over-simplistic;
* The assumptions about commuting are unrealistic. Commuting patterns change over time and it should be one of the objectives of a plan to reduce longer distance commuting in the interests of sustainability. Conversely however this plan is likely to lead to significant increases in commuting (see Section 6 below). The assumption that the commuting rate will remain as in 2011 is therefore naive and lacks any credibility;
* Much of the increase in population in Coventry over the past ten years or so appears to be related to the growth in student numbers in the city. A huge amount of development of student accommodation has taken place. The SHMA never properly addresses this issue. It fails to consider whether and to what extent these trends are likely to continue into the future; or the extent to which students require separate housing provision (as opposed to living in halls of residence or shared accommodation). Why should there not be a 'partial return to trend' on this issue, as on headship rates?
* International migration is mentioned in section 3, but there is no discussion of whether past trends are likely to continue. The Government is under intense political pressure on this issue and has maintained its target of lowering net in-migration by more than half. The outcome of the EU referendum is also likely to have a bearing on international migration. In recent years, Coventry has taken more than its fair share of in-migrants. There is no reason to think that in-migration to the city can or will continue at anything like recent levels. In Warwick District, net migration (including international migration) has varied greatly from year to year since 1995 and is inherently unpredictable. Also, net migration is influenced by housing and employment provision so there is an element of circularity in any forecast which is based on past trends;
* The relationship between affordable housing and overall housing need is never convincingly established by the study. Affordable housing should be a sub-set of overall need, not an 'add-on', so Hearns' upwards adjustment of OAN to take account of affordability appears unjustified. It is also debatable whether 'affordable housing' is affordable in practice to many new households. There is no evidence that Hearns have taken sufficient account of recent changes in government policy.
To sum up, the SHMA is a seriously flawed piece of work that should not have been used without critical analysis. At best the resultant so-called Objectively Assessed Need is subject to great uncertainty; at worst it is not credible at all.
4. Defects in the Way the SHMA Has Been Interpreted and Used
Government guidance is that Objectively Assessed Need should be a starting point for assessing what housing provision should be. The National Planning Policy Framework (NPPF) recognises that there may be circumstances in which development requirements cannot be met because of the demonstrable lack of environmental capacity.
In a letter in December 2014 , the then minister said 'A Strategic Housing Market Assessment is just the first stage in developing a Local Plan and councils can take account of constraints that indicate that development should be restricted.... The outcome of a Strategic Housing Market Assessment is untested and should not automatically be seen as a proxy for a final housing requirement in Local Plans......Councils will need to consider Strategic Housing Market Assessment evidence carefully and take adequate time to consider whether there are environmental and policy constraints, such as Green Belt, which will impact on their overall final housing requirement.' Unmet needs from neighbouring authorities should be met 'where it is reasonable to do so and consistent with achieving sustainable development' .
The Local Plans Expert Group have drawn attention to a common deficiency in local plans. They conclude that 'despite the clear test set by paragraph 14 of the NPPF, few authorities compile an assessment of the environmental capacity of their area' . They go on to propose that a proportionate Assessment of Environmental Capacity should be an important part of plan making. The local plan making authority should consider the extent to which the plan can meet OAN consistent with the policies of the NPPF.
This type of approach is conspicuously absent in Coventry and Warwickshire. The local authorities in their so-called Memorandum of Understanding and Warwick District Council in its plan have taken a lemming-like approach which is directly at odds with Government policy. They have decided without adequate explanation that Hearn's Objectively Assessed Need of 4,272 dwellings per annum (already an artificially high figure) should be increased still further to a housing target of 4,408. They have then failed to consider whether environmental constraints prevent this new figure being met in its entirety. The Hearn approach and its results have not been subjected to any critical analysis whatsoever and the uncertainty that runs right through the study has simply been ignored. It is sheer folly to pick out a single figure and stick to it come what may. Such an inflexible approach is certain to be found wanting as the implementation of the plan unfolds. Meanwhile a great deal of damage will have been done. The position is even more serious in Warwick because the modification to policy DS20 opens the door for even further housing development in future to meet unspecified housing needs in other areas.
The housing proposals for individual authorities are unjustified, to say the least. Coventry is deemed (without supporting evidence or argument) to be able to accept only 1230 (64%) of its OAN of 1930 per annum. The remaining 700 is distributed (without explanation) between three Warwickshire districts - Nuneaton and Bedworth, Rugby and Warwick. In Warwick's case, this results in proposed housing provision of 18,640 over the full twenty year period to 2031, which is over 55% higher than its own OAN. This is a fundamentally unsustainable and unjustified outcome.
The Warwick Plan gives no explanation of -
a. Why Coventry cannot meet more of its OAN;
b. How the allocation of the excess to other authorities has been decided. The 'redistribution methodology' has not been explained or justified;
c. The account taken of Green Belt, environmental and other policy constraints, both in Coventry and in the surrounding Warwickshire districts, in making this judgement;
d. The wider effects of 'transferring' housing need originating in Coventry to Warwick and other authorities.
The plan also fails to consider the density of new housing development or whether intensification of use of the existing housing stock could be achieved without loss of quality in the urban environment. On most development sites, a density of 35 dwellings per hectare has been automatically assumed, ignoring the variability between sites and their settings and the potential for higher density. By leaving this vital issue unconsidered, the plan fails to provide adequate justification for the link between the vast quantum of new housing development proposed and the huge land area involved.
The Warwick Local Plan is therefore fundamentally unsound and unsustainable, quite apart from its unquestioning reliance on a deeply flawed Strategic Housing Market Assessment. The approach taken is, quite simply, indefensible.
5. Implementation Problems
Government guidance requires the Council to demonstrate the deliverability of the plan . The Council do not seem to have asked themselves whether it is realistic to expect 16,776 dwellings to be built in Warwick District between 2011 and 2029.
The Council claim that 1,483 dwellings were completed in the district during the first four years of the plan period - 2011 to 2015: an average of 371 dwellings per annum. The plan requires an average of 932 dwellings per annum to be built over the full plan period, including those first four years. If dwellings built in the first four years are discounted, the average for the remaining fourteen years rises to 1,092 dwellings per annum, nearly three times the rate achieved in the first four years (during which the economy was growing). It simply cannot be done.
The Housing Trajectory in Appendix A shows very clearly the unreality of what the Council are proposing. Average completions per annum between 2018 and 2022 are assumed to be some 1,730 per annum, nearly five times the rate achieved in the first four years of the plan. The beginning of this period is a mere two years away and the assumption seems to ignore the lead time required to assemble skilled workers on a very large scale.
The plan states that at April 2016 there will be sites with planning permission for 5,161dwellings. It is very difficult to believe that all these permissions will actually be implemented during the plan period, though that is apparently what the plan assumes (in contrast, for example, to the Rugby Local Plan which assumes low take-up of existing permissions). In reality, allocating many more sites is likely to reduce the take-up rate on existing permissions still further. Over-allocation on this scale would effectively destroy the planning strategy because the Council would surrender control to house builders over where and when dwellings would be built. Adding an arbitrary 'element of flexibility' to housing provision , taking it up to a grand total of 17,557 , makes matters even worse.
A figure of 16,776 dwelling completions by 2029 therefore belongs in the realms of fantasy. National and regional studies have shown that the main factor limiting the scale of house building has been the sharp decline in public sector house building. Despite some recent policy announcements, there is little prospect of a significant revival in house building by this sector. Private sector building has been stuck at around 90,000 dwellings per annum nationally since 2008 and the latest RICS survey indicates that growth in private sector house building slowed considerably during the first quarter of 2016. Overall, housing permissions have exceeded starts by about 50,000 dwellings per annum nationally in recent years .
A recent study by The Guardian newspaper showed that the nine largest national house building companies were sitting on planning permissions for 615,000 dwellings. Either they were incapable of building more because of shortages of labour, materials and / or finance; or effective demand is so low that they had no confidence that they could sell houses if they were built, or they chose to limit their output in order to keep house prices artificially high. Some house builders may also see investment in land as an end in itself in view of rising land prices. The truth probably lies in some combination of these factors. House builders have recently been criticised for 'land banking' by the Local Government Association.
So the prospects of 16,776 dwellings being built in Warwick by 2029 are negligible. Even so, house builders continue to press for high levels of provision so that they will have even more scope to pick and choose the sites that will bring them the greatest profits. This is understandable from their point of view, but should never form part of a credible planning strategy.
6. Likely Effects of the Housing Policies
As a result of this serious over-provision, the plan's housing proposals will have a wide range of unintended consequences -
a. The sites that provide developers with the greatest potential profit will tend to be green field sites outside urban areas rather than brownfield sites within them. The momentum behind urban regeneration will therefore be weakened still further and it will become much more difficult to redevelop windfall sites becoming available within the urban area. The Local Plan is right to have made an allowance for windfalls, but the more green field sites they allocate for housing development, the more difficult it will become to benefit from windfall sites;
b. Over-provision of housing can be expected to accelerate vacancy rates, dereliction and decay in the existing stock, particularly in the more marginal housing areas;
c. The displacement of housing from Coventry into Warwickshire will increase longer-distance commuting and lead to greater car dependency. No proper analysis has been done of this vital aspect of the proposals, least of all by the Sustainability Appraisal. Can the road and public transport systems cope with the extra traffic and passengers? With many roads, particularly in the towns of Warwick, Leamington Spa and Kenilworth, close to or above capacity already, the strong suspicion must be that the Warwick plan is unsustainable in transport terms. Where new roads or improvements to existing roads are proposed, insufficient information is given to demonstrate their financial viability or effectiveness in dealing with congestion;
d. A more dispersed pattern of development will lead to higher service and infrastructure costs once existing capacity thresholds have been exceeded, and will divert severely limited public sector resources away from renewal of services and infrastructure within existing urban areas . Developer contributions are rarely sufficient to provide necessary supporting services and facilities in their entirety;
e. Provision at a level not supported by effective demand is particularly destructive of the housing opportunities available to newer, younger and less well-off households: those most likely to be in housing need. New housing will overwhelmingly not be purchased by newer households. It is not valid to assume that a glut of new housing will result in lower prices all round, making the existing stock more affordable to those in housing need. In practice new homes are generally such a small proportion of the total housing stock that they do not have a significant lowering effect on prices;
f. Very substantial areas of Green Belt will be lost, compounded by losses for other purposes such as the sub-regional employment site. Proposed housing development in the plan accounts for some 500 hectares of Green Belt land and much of this is in strategically significant areas where the Green Belt performs vital functions, meeting all or most of the five purposes of Green Belt. It is very revealing that the plan does not make clear that meeting housing needs is not sufficient on its own to constitute the very special circumstances needed to justify inappropriate development in the Green Belt (see below) and that it generally ignores the recommendations of the Joint Green Belt Study;
g. Rigid adherence to forecasts gives only the illusion of certainty, inhibiting necessary adaptations to new problems and unforeseen opportunities . Warwick and the other Coventry and Warwickshire authorities have chosen to adopt a particularly rigid and unresponsive interpretation of present government policy and their proposals are therefore doomed to fail in practice.
These potential impacts of the Warwick Plan's housing proposals render the plan unsustainable and therefore not in compliance with government policy in the National Planning Policy Framework.
In particular, the plan fails to give sufficient weight to two key aspects of government policy:
a. That the presumption in favour of sustainable development does not apply in the Green Belt ;
b. That need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt. In July 2013, Local Government Minister Brandon Lewis said that 'The single issue of unmet demand....is unlikely to outweigh harm to the green belt and other harm to constitute the 'very special circumstances' justifying inappropriate development in the green belt' This was followed by a DCLG policy statement in October 2014 - 'the local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability....of land...and take account of any constraints such as green belt which indicate that development should be restricted and which may restrain the ability of an authority to meet its need . This was in turn reflected in Planning Practice Guidance . Yet Warwick District Council, along with the other Coventry and Warwickshire authorities, seems to have ignored this very important element of government policy .
The Sustainability Appraisal has been updated to reflect the latest modifications to the plan and specifically the huge uplift in housing numbers. However it suffers from a major weakness: that it treats the Strategic Housing Market Assessment and the local authority Memorandum of Understanding as givens without subjecting them to sustainability appraisal in their own right. In general it does not apply sufficiently rigorous analysis and places exaggerated faith in mitigation measures. It plays down some negative effects because of uncertainty about the exact form development will take. It also makes some very questionable individual assessments - for example that the effect of high growth on public transport and community services and facilities will be positive, when experience suggests that provision of these facilities and services almost invariably lags well behind housing development, particularly when it takes place as rapidly as is envisaged in this plan. A positive assessment of the high growth options against 'reduce need to travel' also seems fundamentally misguided when such a high proportion of the proposed development involves meeting Coventry's housing needs in Warwick District.
Impact on the Green Belt should have featured as one of the sustainability criteria used to appraise the plan and its policies. Green Belt is simply subsumed within the much wider criterion of 'Prudent Use of Land and Natural Resources' and it tends to get lost in the process. The appraisal frequently pulls its punches, talking for example about the potential for the loss of Green Belt when the strategy entails certainty of massive Green Belt loss.
Nevertheless the Sustainability Appraisal finds that the two high growth options (900 and 1,000 houses per annum) would have negative effects in relation to six of the sustainability criteria used to assess options. This conclusion is effectively ignored in the plan itself and there is no evidence that it has played any part in the development of the strategy. The Council have wrongly assumed that they have no alternative but to meet so-called Objectively Assessed Need in full, plus the huge uplift to meet Coventry's excessive housing needs.
7. Comments on Specific Housing Policies and Proposals and their Justification
My calculations suggest that some 4,575 (49%) of the new dwellings on specifically allocated sites would be in the Green Belt. This is a staggering figure which cannot possibly be reconciled with Government policy as described above. It is difficult to imagine why Warwick District Council, given the large amount of its land area subject to Green Belt policy, agreed to accept by far the largest individual proportion of Coventry's overspill (6,640 dwellings). On the basis of conflict with government policy and the need to preserve a strong Green Belt to secure the continued separation of the towns in the district from each other and from Coventry, I object to all the locations for housing development listed in paragraph 2.81 as having been removed from the Green Belt.
My comments on selected proposals are as follows:
* Kings Hill (H43) - This development would be a huge and totally unwarranted projection of the built-up area of Coventry into the Green Belt and open countryside south of the city. It would doubtless be followed soon afterwards by an application for a boundary revision to extend the city's area. This is an area of good quality landscape which makes an important contribution to the role of the Green Belt in separating Coventry from Kenilworth. The proposal relies heavily on a new railway station and roads but given the long delay in securing reopening of Kenilworth station there can be no guarantee that a station at Kings Hill will be open before development takes place.
* East of Kenilworth (H40) - This long swathe of development would close the Green Belt gap which currently exists between the built-up area of the town and the A46. On rising ground, the development would be very visible from countryside to the east near Ashow and the National Agricultural Centre.
* North of Milverton (H44) - This would constitute a substantial northward extension of Leamington Spa into the Green Belt, bringing it significantly closer to coalescence with Kenilworth. The safeguarding of a large area of additional land for future development makes the present proposal just the thin end of the wedge. The explanation talks blithely about dualling the A452 but this is unlikely to be feasible within the existing built-up area of Leamington and may not be affordable in any case.
* Baginton (H19) - The Rosswood Farm site, almost in line with the airport runway, seems particularly ill chosen from the point of view of noise, air pollution and air safety.
* Barford (H48 et al) - The cumulative impact of these developments would be expected to have a substantial impact on the character of the village.
* Bishops Tachbrook (H49 and H23) - Taken together, development of these sites could be expected to have a profound effect on the character of the village and would involve projections into open countryside to the west and south.
* Cubbington (H50) - A substantial projection of development into pleasant open countryside east of the village.
* Hampton Magna (H51 and H27) - Taken together, these developments would represent a huge extension of the village into Green Belt and open countryside to the south and east, changing the character of the village in the process.
* Leek Wootton (DS NEW 3) - Although a minority of the site was already developed, this does not justify the proposal, which forms a very substantial westward extension of the village into open countryside and Green Belt.
* Whitnash (H-03) - Whitnash is already a peculiarly shaped and poorly accessed urban extension. This large development will add an extension to the extension, taking the village across the railway to the east and making it stick out even more like a sore thumb. It is noticeable that there is no proposal for a railway station to serve it.

Policy DS New 1 includes vague criteria for allocating land for housing south of Warwick. It is wrong in principle to consult without more clear-cut proposals, leaving local people and interest groups in a position of great uncertainty.
The plan is far too deferential towards the growth aspirations of Warwick University. The plan should not give the university carte blanche to do whatever it wishes to do, but that in effect is what is proposed.
A general problem is the heavy reliance on master planning for comprehensive development of the larger proposed housing sites. This will make it even less likely that the housing proposals will be implemented on anything like the timescale envisaged in the housing trajectory, particularly where land is in multiple ownership.
In new paragraph 1.09, the plan talks about new development enhancing the setting of natural and heritage assets. This is delusional and makes a mockery of what little remains of the plan's environmental credentials.
New paragraphs 2.1 to 2.43 talk about taking land out of the Green Belt so that it can be safeguarded for possible future development. In relation to government policy, there is even less of a case for this than where development is claimed to be needed during the plan period, and I have already shown that the latter is contrary to government policy.
I have not found a policy directed towards controlling or influencing the types and sizes of dwelling to be constructed in the district. This plan seems to treat planning for housing as no more than a numbers game and in doing so it ignores government policy that the nature of new housing is important .
8. Conclusions
The housing proposals in the emerging Warwick Local Plan are unworkable, unsustainable, contrary to key elements of Government policy and against the interests of residents of the borough. They are deluded and unsound. They stem from a fundamentally misconceived growth-orientated strategy that reflects wishful thinking about the economic prospects of the sub-region by the Local Enterprise Partnership and the Coventry and Warwickshire local authorities compounded by some far from independent technical work of questionable quality to support it. The proposals give minimal weight to the environment and character of the district, which have hitherto been cornerstones of successive plans. They will result in the Council effectively abandoning control over planning for housing and in a significant reduction in environmental quality.
Much of the problem with the housing strategy stems from Coventry's overweening growth aspirations, which result in dumping large quantities of housing and employment development on neighbouring local authorities. This is counter-productive, unsustainable and unachievable. If Coventry cannot live within its means, it should not simply decant large-scale development to neighbouring authorities with no thought for the consequences..
The question of what would be a realistic and achievable level of housing provision for Warwick between 2011 and 2029 is a matter of judgement rather than calculation. Taking into account all the factors discussed in this Critique, my view is that provision of between 10,000 and 10,500 dwellings would be appropriate. This would have a good prospect of being achieved and would meet the reasonable housing needs of the district, as opposed to the inflated figure assessed by G L Hearn and the huge additional uplift provided through overspill from Coventry. Provision at this level would allow a much higher proportion of development to be on brownfield sites within the urban area (including windfalls) and would require little or no release of Green Belt land for housing.

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

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

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

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

The land North of Milverton should remain in the Green Belt. If it is lost, it is gone forever.
The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.
In short:
* There is no viable reason why green belt land of such value north of Milverton should be used to support Coventry City Council's housing need.
* The "Exceptional Circumstances" needed to remove this land from the green belt do not exist. There are lower value green belt sites closer to Coventry which on the basis of planning precedent should be used in preference to the land in Old Milverton.
* The idea that Warwick District Council should promote commuting from Old Milverton to Coventry is ill conceived, irresponsible and bad planning.

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

See attached

I believe that Modifications 16 and 14 are unsound because:

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.

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

In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need. The costs of houses in the Leamington area will also be higher than in Coventry restricting the viability of people buying houses with the express purpose of commuting to Coventry. This is not the best financial option for the council in helping boost affordable housing.

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

The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
In short rather than adding value to the area this development will degrade it and create unnecessary pressure on the road network going in and out of Leamington - which is already stretched to say the least!

The proposed park-and-ride scheme is unsustainable because:
* There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
* The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
* Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
* There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical
I believe that in order for Modifications 16 and 14 to become sound:

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

See attached

See attached

see attached

See attached

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

The exceptional circumstances required by the national planning policy framework to remove the land north of Milverton form the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the 'value' of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC in cooperation with Coventry City Council has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The 'green lung' between Leamington and Kenilworth will be reduced to less than 1.5 miles.
The picturesque northern gateway to the historic Regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
There will be no dedicated buses so users will have to time visits to coincide with the bus timetable
the site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A542, which could form part of the Thickthorn development and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry
Much of the traffic using the A452 crossed to the south of Leamington where there are the major employers
Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
Oxford appears to have the only park and ride scheme in the country that really works and this is because there is such limited parking in Oxford city centre
There are already lots of car parks in this are of Green belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

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


The exceptional circumstances required by the national planning policy framework to remove the land north of Milverton form the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the 'value' of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC in cooperation with Coventry City Council has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The 'green lung' between Leamington and Kenilworth will be reduced to less than 1.5 miles.
The picturesque northern gateway to the historic Regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
There will be no dedicated buses so users will have to time visits to coincide with the bus timetable
the site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A542, which could form part of the Thickthorn development and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry
Much of the traffic using the A452 crossed to the south of Leamington where there are the major employers
Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
Oxford appears to have the only park and ride scheme in the country that really works and this is because there is such limited parking in Oxford city centre
There are already lots of car parks in this are of Green belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

See uploaded attachment

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See attached

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