H44 - North of Milverton
Object
Proposed Modifications January 2016
Representation ID: 69372
Received: 03/04/2016
Respondent: Mr. Louis Skiffington
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Loss of green belt would impact on future generations the environment and character of Leamington would suffer irreversible damage.. There would be a huge impact on wildlife and on the quality of life for residents.
The green belt is to prevent urban sprawl. Once it is breached it could be the beginning of a land rush with more land being banked for future development. The trend for increasing housebuilding in the green belt will erode our countryside effect wildlife habitats, carbon capture, food production and the prevention of flooding. The csense of well being derived from the countryside will also be destroyed.
Brownfield sites should be regenerated first. Economic growth does not constitute exceptional circumstances for development in the green belt. No exceptional circumstances exist and Coventry Council should look closer to home for sites as north of Leamington will not help their housing problems. The area provides valuable farming land.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69375
Received: 12/04/2016
Respondent: Christopher Sutton
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The green belt should remain as it is north of Leamington and the proposed allocation deleted. The housing need to cater for Coventry overspill should be better located to Coventry and on more sustainable transport routes/ social infrastructure.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69377
Received: 12/04/2016
Respondent: Mrs. Christine Sutton
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
If land is to support Coventry's needs, unlikely that people from Coventry will live here.
Suitable sites closer to Coventry on land of lower green belt value.
Loss of farmland.
Park and ride unworkable - no dedicated buses and sufficient parking in Leamington.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69401
Received: 21/04/2016
Respondent: Dr Martin Davis
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
No exceptional circumstances have been demonstrated to justify removal of land and allocation for housing.
Development should be reallocated closer to Coventry which is of lower Green Belt value.
Proposal for park and ride would not work
Increase in traffic congestion
The development would destroy the rural character of Milverton
See attached
Object
Proposed Modifications January 2016
Representation ID: 69409
Received: 22/04/2016
Respondent: Old Milverton & Blackdown JPC
Agent: Hunter Page Planning
Legally compliant? Not specified
Sound? Yes
Duty to co-operate? No
is the position of Old Milverton and Blackdown Joint Parish Council that the proposed strategic allocation at Old Milverton will not meet the needs of Coventry and is not suitable for such purposes.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69415
Received: 21/04/2016
Respondent: Jane Greasley
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
This proposal would mean the "green lung" between Kenilworth and Warwick is reduced to less than 1.5 miles. The proposals will destroy the approach to the historic town. Highly productive farmland will be lost together with wildlife habitats. This area is highly valued for recreation. The railway station would be unviable due to the construction required.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69420
Received: 17/04/2016
Respondent: Alison Williams
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Exceptional circumstances have not been demonstrated. Brownfield sites nearer Coventry should be available.
These fields act as important green lung between Kenilworth and Leamington and are highly valued for recreation as well as being important for wildlife and biodiversity. This is productive farmland which also soaks away water to prevent flooding. It is unlikely that people who want to live in Coventry will want housing in Milverton.
The park and ride scheme is unnecessary and unsustainable as the site is too close to Leamington.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69422
Received: 19/04/2016
Respondent: Mrs J M Warr
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The housing demand is from Coventry and sites should be in that area. the increased travelling by developing here will increase congestion. The development would impact on the attractive approach to the town. High value green belt land will be lost. This is productive farm land and an important local amenity. It is also important for wildlife
the park and ride has no decent bus service and is not of value to shoppers . Any railway station would be impossible to construct nd would be too near Kenilworth station. Drainage and sewerage problems will be exacerbated by the proposed housing.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69426
Received: 19/04/2016
Respondent: Mr. Michael Warr
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Exceptional circumstances have not been demonstrated for removal of this area from the green belt. Sites closer to Coventry would be more sustainable - for instance extra traffic would be counter-productive. The traffic would also increase pollution. The proposals also require unnecessary road improvements. The high house prices in this location are unlikely to accommodate Coventry's working population. the proposals would impact on the character and attractiveness of this area. this land is highly valued by locals and is productive farmland.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69430
Received: 18/04/2016
Respondent: Mr J C Clack
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Exceptional circumstance for release of the land north of Milverton from the Green Belt have not been demonstrated. The site is needed to support Coventry's need. There are more appropriate sites closer to Coventry. This site will cause unnecessary commuting, and congestion and road building.
This area provides productive farmland. It also provide important habitats for a range of wildlife and contains mature hedgerows. The open nature of the land also enable water to soak away and restores aquifers.
Housing in this area will exacerbate flood risk and potentially subsequent pollution of watercourses.
Traffic congestion is compounded by problems at Thickthorn A46 junction. Development north of Milverton, combined with development at Thickthorn means this will get worse and not even a dual carriageway will assist. In addition there will be problems for emergency vehicles.
The proposed park and ride would means buses are caught up the gridlock - the park and ride at Stratford has not worked.
There is no requirement for Coventry's residents to move here, so how does the proposal meet Coventry's needs.
the proposed railway station would be costly and track restrictions would mean services are infrequent.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69439
Received: 03/04/2016
Respondent: Mrs Beverley McDonagh
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Park and ride scheme not required - if it was, should be located close to A46
Coventry housing shortfall should be sited near Coventry - minimise commuting and pollution
Green belt prevents coalescence in this location
see attachment
Object
Proposed Modifications January 2016
Representation ID: 69445
Received: 22/04/2016
Respondent: Mr. Simon Stribblehill
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Exceptional circumstances don't exist to remove land from green belt.
Sites closer to Coventry should be used.
Park and Ride not appropriate.
Car parking will exacerbate flooding
Lack of demand.
Adverse impact on sensitive and attractive landscape.
Adverse impact on recreational amenity
Loss of green belt
Additional traffic and congestion
Lack of supporting infrastructure
See attached
Object
Proposed Modifications January 2016
Representation ID: 69491
Received: 18/04/2016
Respondent: Mary Horne
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
-There is enough land in Coventry to take their overflow.
-There will be great loss of wildlife and habitat.
-Loss of farmland which affect farmers.
-With all the proposed houses there will be pollution.
-There will be drainage problems.
-The peace & quiet in the area will be drowned with noise of cars, etc.
-We do not need another railway station.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69496
Received: 04/04/2016
Respondent: James Plaskitt
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The allocation of this site conflicts with Coventry and Warwick's objectives. In the case of Coventry, the Plan focuses on employment growth. As a result this allocation means that employment growth is not co-located with housing growth. Warwick's plan seeks to only allocate green field sites where they are located close to areas of employment. This is not the case. Further the site is not appropriate, particularly as Coventry seek to bring forward sites adjacent to the City boundary to avoid in-commuting. So the site is inconsistent with the plan's objectives.
In this context Kings Hill is far more logical
See attached
Object
Proposed Modifications January 2016
Representation ID: 69499
Received: 18/04/2016
Respondent: Dr. Martin Simons
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
-There are sites closer to Coventry that should be used in preference to that proposed.
-People in Coventry are unlikely to buy homes North of Milverton.
-Precedence for releasing land from greenbelt requires 'value' from the potential sites to be taken into account. Sites close to Coventry are of lower greenbelt value.
-The 'green lung' between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.
-Highly productive farming land and wildlife habitat will be lost.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69505
Received: 20/04/2016
Respondent: Cllr Bill Gifford
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
In order for Modifications 14 and 16 of Warwick District's Local Plan to be sound, the land to the north of Milverton would have to remain in the Green Belt. Warwick District Council has not provided the evidence of Exceptional Circumstances to justify removing the land to the north of Milverton from the Green Belt. There are sites adjacent to Coventry that could meet Coventry's Housing need and are deliverable.
I would argue that the decision to remove the land to the North of Milverton from the Green Belt for development is not justified, is not effective and is not consistent with the National Planning Policy Framework.
It is not justified because removing the land to the north of Milverton from the Green Belt and developing 250 dwellings and "Safeguarding" further land for future development does not meet Coventry's Housing Need. Clearly, the most sustainable locations to meet Coventry's Housing Need will be those closest to Coventry and with easy access to that city.
It is clear that Coventry City Council acknowledges this within its own emerging Local Plan, when it states: "The Council is committed to continued and constructive engagement, through the Duty to Cooperate, with its Warwickshire neighbours to secure the most appropriate and sustainable locations for housing growth across the HMA. In reflection of the Warwickshire authorities supporting the delivery of the city's wider housing need, where it is shown to be desirable, appropriate, sustainable and deliverable the Council will support its Warwickshire neighbours in bringing forward land for housing and employment that sits adjacent to the city's existing administrative boundaries [my italics]. This will ensure infrastructure needs are met in full across administrative boundaries (where necessary and as appropriate) and support the continued growth of the city as the central point of the sub-region." Clearly, the land to the North of Milverton is not adjacent to the City's existing boundaries.
For reasons of sustainability, and to improve air quality, Coventry City Council in its emerging Local Plan states it is keen to cut down on car journeys to work. Of the relatively small percentage (12.3%) of Milverton residents who work in Coventry, the overwhelming majority (88.72%) commute by car and none by train. It is clear that developing the land to the north of Milverton will do nothing to meet Coventry's housing need and does not meet the City Council's requirements for sustainable development. In DS New 1 of Coventry City Council's Local Plan they state: "A reduced need to travel will promote increased levels of walking, cycling and use of public transport. This will contribute towards reduced carbon emissions and improve the urban environment. This will have a positive effect on public health and wellbeing." I have to agree with this statement. The proposal by Warwick District Council for the land to the North of Milverton would increase car journeys with all the adverse effects that implies.
As for the economic growth that Coventry wishes to pursue, the removal of land from the Green Belt to the north of Milverton will not help Coventry's needs. Indeed in DS1 New of Coventry City Council's Local Plan it states there is a risk of development beyond its boundaries: "There is a risk that new homes, employment, retail and leisure opportunities will be developed outside of the city. This could see investment diverted elsewhere and put at risk the city centre regeneration strategy." Building to the north of Milverton does nothing to alleviate that risk to Coventry. Indeed, given the competing nature of Leamington's town centre, it increases that risk.
Warwick District Council claims that it has used a three-stage approach to decide on the Exceptional Circumstances on any particular site in the Green Belt:
1. Is there an essential need that has to be met? If yes,
2. are there any suitable sites outside the Green Belt that can meet this need? If no,
3. is this the best site within the Green Belt to meet the need (taking account of the Green Belt study as well as other aspects of the site assessments)? If yes, then there are exceptional circumstances to release a site from the Green Belt and allocate it in the Local Plan.
Given Coventry's housing need, Warwick District Council has to show there is an essential need that has to be met. Given that all the land to the north of Leamington and Warwick is in the Green Belt, it is difficult to see how Coventry's identified housing needs can be met without using some Green Belt land within Coventry's own boundaries or within Warwick District. But the vital question is the third one, are there exceptional circumstances to release a particular site from the Green Belt and allocate it to the Local Plan? The District Council does not provide evidence that it has assessed the sites in order of their contribution to the Green Belt.
Warwick District Council appears to rely on deliverability as an argument as to why less than half of Coventry's Housing Need that it is taking within Warwick District's boundaries is to be built adjacent to Coventry. WDC argues that although the King's Hill site can take more than 4,000 dwellings in land adjacent to Coventry, developers cannot deliver more than 1,800 there within the time frame. Given that the most of the land to the north of Milverton that is to be removed from the Green Belt is to be safeguarded and possibly used after the 5-year review, that would suggest it is basically being held in reserve should Coventry's housing need be greater than expected. That would suggest that, as elsewhere in the country, it should be possible in that case to deliver quite considerably more than 200 dwellings per annum on a site such as King's Hill that is adjacent to Coventry. Indeed in other parts of the country on sites of 3,000 or more as many as 500 houses a year have been deliverable.
Warwick District Council does not provide significant evidence to back up its claim that there are not sufficient deliverable sites on the edge of Coventry. In essence it makes a statement without backing that up with the evidence.
The proposed park-and-ride scheme to the North of Milverton does not appear to be evidence based. A senior Council officer at Warwick District has stated in public at a recent joint meeting of the Overview and Scrutiny Committee and the Finance and Audit Committee that: "In the Local Plan there is possible provision for Park and Ride. For Park and Ride to be viable you have to take out car parking capacity from the town centre." This was a meeting in which a major proposal was the replacing of an existing car park with a new and enlarged car park. Leamington Spa is not an old medieval town with narrow streets and little on-street car parking. It is a town built on a grid pattern with wide streets and plenty of on-street car parking. I would suggest that the proposed Park & Ride is not viable. I would also suggest that any attempt to try and make it viable by a substantial increase in car parking fees or closing of car parks would have serious effects on the economic success of the town's economy.
Warwick District Council has failed to provide the "Exceptional Circumstances" required to remove the land to the north of Milverton from the Green Belt and is therefore not consistent with the National Planning Policy Framework. It is also neither effective nor justified.
Warwick District Council claims that it has used a three-stage approach to decide on the Exceptional Circumstances on any particular site in the Green Belt:
4. Is there an essential need that has to be met? If yes,
5. are there any suitable sites outside the Green Belt that can meet this need? If no,
6. is this the best site within the Green Belt to meet the need (taking account of the Green Belt study as well as other aspects of the site assessments)? If yes, then there are exceptional circumstances to release a site from the Green Belt and allocate it in the Local Plan.
Given Coventry's housing need, Warwick District Council has to show there is an essential need that has to be met. Given that all the land to the north of Leamington and Warwick is in the Green Belt, it is difficult to see how Coventry's identified housing needs can be met without using some Green Belt land within Coventry's own boundaries or within Warwick District. But the vital question is the third one, are there exceptional circumstances to release a particular site from the Green Belt and allocate it to the Local Plan? The District Council does not provide evidence that it has assessed the sites in order of their contribution to the Green Belt.
Warwick District Council appears to rely on deliverability as an argument as to why less than half of Coventry's Housing Need that it is taking within Warwick District's boundaries is to be built adjacent to Coventry. WDC argues that although the King's Hill site can take more than 4,000 dwellings in land adjacent to Coventry, developers cannot deliver more than 1,800 there within the time frame. Given that the most of the land to the north of Milverton that is to be removed from the Green Belt is to be safeguarded and possibly used after the 5-year review, that would suggest it is basically being held in reserve should Coventry's housing need be greater than expected. That would suggest that, as elsewhere in the country, it should be possible in that case to deliver quite considerably more than 200 dwellings per annum on a site such as King's Hill that is adjacent to Coventry. Indeed in other parts of the country on sites of 3,000 or more as many as 500 houses a year have been deliverable.
Warwick District Council does not provide significant evidence to back up its claim that there are not sufficient deliverable sites on the edge of Coventry. In essence it makes a statement without backing that up with the evidence.
Within the Local Plan it mentions that a railway station could be built at Old Milverton. This seems to have been chosen without any meaningful discussion with the County Council that has for some time been working on the 'Knuckle' project. A new station is being built at Kenilworth but no suggestion has been made about a station at Old Milverton. The evidence that is available suggests that nobody in Milverton uses the train at the moment to commute to Coventry. In all my years as a District and County Councillor, no resident has suggested opening a new station at Old Milverton. A railway station is also unviable because the railway line is in a deep cutting in Old Milverton, making construction impractical.
District Council has also failed to provide the "Exceptional Circumstances" required to remove the safeguarded land to the north of Milverton from the Green Belt and is therefore again not consistent with the National Planning Policy Framework. It is also neither effective nor justified.
In summary, in order for Modifications 14 and 16 of Warwick District's Local Plan to be sound, the land to the north of Milverton would have to remain in the Green Belt. Warwick District Council has not provided the evidence of Exceptional Circumstances to justify removing the land to the north of Milverton from the Green Belt. There are sites adjacent to Coventry that could meet Coventry's Housing need and are deliverable.
Object
Proposed Modifications January 2016
Representation ID: 69531
Received: 12/04/2016
Respondent: Dr Alexandra Tansey
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Exceptional circumstances for the removal of this land from the green belt have not been demonstrated. Highly productive land will be lost as well as established wildlife habitats and a green lung between Kenilworth and Leamington. This area is highly valued for recreation. This would lead to commuting to Coventry on already over-congested roads.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69540
Received: 21/04/2016
Respondent: Dr. & Mrs. Adrain & Margaret Newell
Number of people: 2
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
-'Exceptional Circumstances' required by NPPF not met
- land available near Coventry available - would reduce commuting, congestion and road building.
- houses will not be used by Coventry people
- 'green lung' will be reduced.
- Farmland and wildlife habitat will be lost.
- area of leisure for residents will be lost.
- Park and ride scheme will be of no use - no dedicated buses, site too close to Leamington, such schemes used only in large towns, only non-residents use this scheme.
- Leamington a small historic town with narrow streets and turns.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69541
Received: 22/04/2016
Respondent: Mr. Scott Moore
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
-The 'exceptional circumstances' required by NPPF is not demonstrated.
-The purpose of greenbelt is to prevent urban sprawl. Developing this area will reduce the distance between Leamington and Kenilworth to 1 1/2 miles.
- Much lower value green belt land is available near Coventry for the development.
- Loss of productive farming land, established wildlife and area valued by the community for walking, running, etc.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69562
Received: 16/04/2016
Respondent: Mr Michael Lambert
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Park and Ride development is considered unsustainable because:-
- there is insufficient demand by visitors;
- the end destination has sufficient parking;
- there is insufficient time advantage in the location.
Better alternative locations exist - eg: adjacent to the A46.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69581
Received: 19/04/2016
Respondent: Rob & Donna Clifton
Number of people: 2
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
- Sites should be considered near or within Coventry City to fulfil Coventry's requirement.
- Loss of highly productive farming land and wildlife habitat.
- Park and ride scheme will increase length of time for commuters journey and add to congestion.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69592
Received: 18/04/2016
Respondent: Joan Bowden
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
- Exceptional circumstances are not stated
- sites on edge of Coventry of less green belt value and should be used first
- Area north of Milverton is of great value for walking, running and natural history.
- Area provides a 'green lung' between Kenilworth and Leamington.
- It is a productive farming land with rich wildlife habitat.
- Coventry public will be better served by new homes being built nearer to Coventry
- need to reduce journeys to work
- increased traffic will be exacerbated by additional houses.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69632
Received: 14/04/2016
Respondent: Mr Roger Johnson
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
- Exceptional circumstances not justified
- Land has high value, residential properties to be built would likely be of high value and as these properties would be much closer to Leamington and Kenilworth than to Coventry, they would be more attractive to live and work in those locations, than in Coventry.
- Proposed plan will add problems caused by commuting like increase in traffic, poor air quality, etc.
- Park and Ride scheme unsustainable
- new station would require significant infrastructure
See attached
Object
Proposed Modifications January 2016
Representation ID: 69676
Received: 21/04/2016
Respondent: Claire Fuller
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
No exceptional circumstances to remove land north of Milverton (H44) from the Green Belt
There are lower value Green belt land nearer to Coventry
See attached
Object
Proposed Modifications January 2016
Representation ID: 69682
Received: 22/04/2016
Respondent: Mr Ian Biddlecombe
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
I am concerned that these proposals to support housing for Coventry will increase traffic locally and lead to further congestion. The local road network is already stretched to beyond capacity. Also a lot of amenity land will be lost and the green gap between Leamington and Kenilworth will be reduced further.
Wildlife habitats will be lost and traffic noise levels and pollution will increase.
The area is used by a lot of dog walkers and ramblers and these activities will not be possible with the proposals.
see attached
Object
Proposed Modifications January 2016
Representation ID: 69701
Received: 20/04/2016
Respondent: Mr. Philip Jeary
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The exceptional circumstances do not exist for removing land North of Milverton from the Green belt. It would affect the openness of the countryside
Road infrastructure would not cope with extra development
Development would be unsustainable and increase commuting
See attached
Object
Proposed Modifications January 2016
Representation ID: 69737
Received: 22/04/2016
Respondent: G. Lightfoot
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
- Local residents will lose a vital green space, which is used for walking, running, etc.
- Increase in traffic and flood.
- Better to build near Coventry's site.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69738
Received: 22/04/2016
Respondent: Professor David Hardiman
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The site will extend northern border of Leamington into greenfield land.
Important green lung and leisure facility. Without this open space residents would be forced to drive to different ones, adding to traffic congestion.
Increase in traffic and congestion.
Adverse impact on character of Old Milverton
Adverse impact on green belt and landscape
Exceptional circumstances have not been demonstrated to justify loss of green belt
See attached
Object
Proposed Modifications January 2016
Representation ID: 69745
Received: 16/04/2016
Respondent: T and J Walter
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Object to allocation: -
- site lies within green belt - no exceptional circumstances have been demonstrated to justify its development
- loss of open space between Leamington and Kenilworth
- should consider land at Kings Hill, Westwood Heath and Hurst Farm
- park and ride unsustainable - insufficient demand and wrong location
See attached
Concerning the process, WDC has obviously done a huge amount of work in coming up with the New Plan - congratulations to you and the team. I understand the background to the revisions, most of which are understandable, supportable and rational.
May I make a couple of suggestions to improve the consultation process which would better demonstrate WDC's commitment to consult? Your online response form is unwieldy, un-user friendly and complex. The downloadable PDF form, being a PDF, cannot easily be used by most to work up a draft response before finalising it. It would then have to be scanned to be sent in electronically. Many of the local electorate to whom you are addressing the consultation cannot cope with this process. I have converted the PDF to a Word document (to help you have my views in your preferred format) but it would be so much easier if the form was available in Word in the first place.
Object
Proposed Modifications January 2016
Representation ID: 69819
Received: 20/04/2016
Respondent: Mark Aynsley
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Object to allocation: -
- better sites available
- loss of green belt not justified - no exceptional circumstances
- loss of recreational amenity
- adverse impact on character of area
See attached