Preferred Options 2025

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No

Preferred Options 2025

Do you broadly support the proposals in the How to Have Your Say chapter? If you have any additional points to raise with regards to this chapter please include them here.

Representation ID: 98718

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

Although carefully structured, it is very long, and to understand it fully it is necessary to read many more documents than just the 187 pages of the consultation paper itself. The number of supporting documents and the level of detail are too onerous for members of the public and other non-specialists (e.g. town and parish councillors) to be able to digest fully. The process therefore appears skewed towards planning professionals who are i) conversant with the terminology/issues and ii) have teams of people and resources to dedicate to it. OMBJPC feels that this should be acknowledged when considering the responses.

Other

Preferred Options 2025

Do you broadly support the proposals in the Vision and Strategic Objectives: South Warwickshire 2050 chapter? If you have any additional points to raise with regards to this chapter please include them here.

Representation ID: 98724

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

OMBJPC supports the aims but notes that building on Green Belt land in SG06 would directly contradict two of the principles:
“A healthy, safe and inclusive South Warwickshire – enabling everyone to enjoy safe and healthy lifestyles...” SG06 offers 22km of footpaths per hectare which are well-used by people from all over Leamington and surrounding areas. It provides physical and emotional benefits as Supporting Document 4 shows.
“A biodiverse and environmentally resilient South Warwickshire.” SG06 is high quality agricultural land, much of it Grade 2. The hedgerows and wildlife support biodiversity, as a WWT has found (see ombparish.org.uk/greenbelt).

No

Preferred Options 2025

Strategic Growth Location SG06 Question

Representation ID: 98744

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

Supporting Documents 1-4 outline OMBJPC’s full position.
Housing need can be met without building on green belt; exceptional circumstances not present.
Flawed analysis and reliance on removed paragraph 142 (NPPF) undermines Green Belt Review and future selection criteria.
SG06 not a ‘sustainable location’; would promote car use.
SG06 fulfils the five purposes of Green Belt, contributing greatly to ‘openness’ and protecting the settings of historic settlements.
SG06 is high quality agricultural land, important for sustainability and security.
Planning Inspectorate rejected similar proposals in 2017.
SG06 already promotes the principles ‘healthy, safe and inclusive’ and ‘biodiverse and environmentally resilient’.

Other

Preferred Options 2025

Do you have any comments on a specific site proposal or the HELAA results?

Representation ID: 98789

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

HELAA metrics indicate that SG06 should not be allocated for development. Much of the area was discounted at Stage A, leaving just two parcels in Stage B:
SG06 (west) scored 52 out of 82 (max), putting it well into the top half of ‘least suitable’ for development.
SG06 (east) scored 69 putting it in the top quarter.
SG06 is quality agricultural land. The development density between Coventry and North Leamington presented by SG01, 02, 03, 04, 06 risks joining these two historic settlements using Kenilworth as a bridge. This is precisely what the West Midlands Green Belt seeks to prevent.

Yes

Preferred Options 2025

Do you agree with the approach laid out in Draft Policy Direction 2 - Potential New Settlements?

Representation ID: 98796

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

The concept of new settlements intrinsically allows for better and more sustainable design. We would support any proposed site which does not over-urbanise the wider West Midlands area and which is not in the West Midlands Green Belt. New settlements should at all costs be avoided in narrow and restrictive parts of the Green Belt. The Green Belt is there precisely to prevent conurbanisation.

Yes

Preferred Options 2025

Do you agree with the approach laid out in Draft Policy Direction 3- Small Scale Development, Settlement Boundaries and Infill Development?

Representation ID: 98799

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

Old Milverton and Blackdown Joint Parish Council supports limited infilling within built up area boundaries within the Green Belt where it does not conflict with the five primary purposes of the Green Belt and where proposals contribute positively to the green/blue agenda.

No

Preferred Options 2025

Do you agree with the approach laid out in Draft Policy Direction 4- Accommodating Growth Needs Arising from Outside South Warwickshire?

Representation ID: 98802

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

OMBJPC is aware that South Warwickshire is bounded by Coventry and Redditch and there may be unmet needs from those areas than have to be accommodated. However, it is clear from the previous Inspector’s Report (2017) that addressed this matter, development to meet the unmet needs of Coventry will need to be located adjoining Coventry, rather than the edge of Leamington. The same principle would apply to Redditch.
In particular, land in the West Midlands Greenbelt should not be used to accommodate housing need from other areas as this would defeat the purpose of the West Midlands Greenbelt.

Other

Preferred Options 2025

Do you agree with the approach laid out in Draft Policy Direction 5- Infrastructure Requirements and Delivery?

Representation ID: 98808

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

The draft policy is not explicit enough. New development should only be allowed to commence once the necessary supporting infrastructure has been agreed, funded and planned for. Development should then take place at a parallel timescale to housing development and not kicked into the long grass.
There is a genuine risk that new development at the scale required will overload or overlook infrastructure requirements. This is therefore perhaps the most important policy of all and should therefore be clear and watertight.

Other

Preferred Options 2025

Do you agree with the approach laid out in Draft Policy Direction 6- Safeguarding land for transport proposals?

Representation ID: 98811

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

This is a sensible principle, but the identified sites themselves may be inappropriately placed if they are identified prior to development areas being chosen.

No

Preferred Options 2025

Do you agree with the approach laid out in Draft Policy Direction 7- Green Belt?

Representation ID: 98815

Received: 06/03/2025

Respondent: Old Milverton and Blackdown Parish Council

Representation Summary:

Our understanding is that Policy Direction 7 is flawed due to its reliance on Paragraph 142 of the old NPPF. This provided scope for authorities to take into account “the need to promote sustainable patterns of development”. It was removed in July 2024.
The current NPPF makes no provision for sustainability being the determining factor for whether green belt land can be used over non-green belt land. The legacy policy (old paragraph 142) is present in the Spatial Growth Strategy and in the Draft Policy Direction 7. It will therefore misleadingly inform the preferred option unless corrective action is taken.

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