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ID sylw: 108154

Derbyniwyd: 04/03/2025

Ymatebydd: Mrs Morag Clarke

Allowing development on SG06 would undermine important principles that the Local Plan is elsewhere seeking to follow:

1. Housing Need
South Warwickshire's housing need can be met without building on green belt land.
The Local Plan is pursuing a spatial growth strategy of 'Sustainable Travel and Economy and identifies 24 potential Strategic Growth Locations as well as 12 potential New Settlements that conform to this strategy. To meet government targets the Local Plan needs to make provision for 30,000 additional new dwellings in South Warwickshire; these to be located in the strategic growth locations and new settlements. However, the Local Plan's own Sustainability Appraisal shows that:
• Strategic Growth Locations that are not in the green belt have capacity for 48,500 dwellings.
• New Settlements that are not in the green belt have capacity for a further 6,000 dwellings.
This means that it is possible to meet housing need without building on green belt land and therefore, exceptional circumstances cannot be met to release green belt sites to meet the housing requirements.
Furthermore, it is clear from comments in the previous Inspector's Report (2017), that development to meet the unmet needs of Coventry will need to be located adjoining Coventry, rather than the edge of Leamington.
Overall, there is no need nor justification for removing green belt land in North Leamington for the purposes of the South Warwickshire Local Plan.

2. Sustainable Locations
The Local Plan purports to put sustainability at its heart and wants new developments to be "20-minute neighbourhoods", where local services, including train stations and bus routes, are within a 10 minute walk. Site SG06 does not comply with this; it is a minimum 30 minutes’ walk to Leamington train station.

3. Green Belt
Since the Town and Country Planning Act 1947 allowed local authorities to include green belt proposals in their development plans, subsequent green belt allocations have served the nation well. The green belt around North Leamington continues to fulfil the current stated purposes of green belt land, to:
• check the unrestricted sprawl of large built-up areas
• prevent neighbouring towns merging into one another
• assist in safeguarding the countryside from encroachment
• preserve the setting and special character of historic towns
• assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Government attaches great importance to Green Belts. SG06 clearly meets all five of the above criteria.
In addition to SG06, numerous other sites along the A452 were put forward in the Call for Sites. Once land is removed from the Green Belt for development this cannot be undone and a precedent is set which makes it easier for adjoining swathes of land to be built on. Therefore, were development to go ahead, the amount of green belt land ultimately lost could be far greater than just the 360 acres of SG06.

4. Flaws in the Green Belt Review
There are fundamental flaws in the Green Belt Review carried out by Arup in 2024.
The main flaw is the rationale for excluding Leamington Spa, Warwick and Stratford-upon-Avon from the definition of 'large built-up area' on the basis that they sit on the edge of the Green Belt, rather than within it.
This leads the Green Belt Review to the presumption '...that the Green Belt was not intended to prevent their growth, and thus it does not seem appropriate to consider them as part of the "large built-up area". This is illogical. If land on the northern edges of Leamington, Warwick and Stratford-upon-Avon was not intended to prevent their outward 'sprawl' it would not have been designated as Green Belt. Their growth was to be accommodated to the south and constrained by Green Belt to the north. In terms of being large built-up areas, Government Planning Inspectors have found other similar sized towns in the West Midlands Green Belt to be 'large built-up areas’.
The assessments of SG06 is also unsound. Of the four parcels of land at SG06, three are assessed as making 'a moderate contribution' to the purposes of the green belt, and one 'a weak contribution? The assessment was primarily desk-based, with just a single visit to a viewing point at each site. The viewing points were:
◦ the entrance to the footpath off Bamburgh Grove
◦ the lay-by north of North Leamington School
◦ the entrance to the footpath off Leicester Lane
◦ the entrance to private fields off Westhill Rd, described in the report as a derelict site.
The essential characteristics of Green Belts are their openness and their permanence, and at least three of these viewing points give no sense at all of the openness of each location. The practice of relying on desk-based judgements without an understanding of the local area is unreliable.
Legal precedent makes it clear that green belt land to the north of Leamington Spa makes a strong contribution to Green Belt Purpose A and this must surely include SG06.

5. SG06 is high quality agricultural land and makes an important contribution to sustainability and security of food supply.
NPPF, 2024 is clear that where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality should be preferred to those of a higher quality. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The land making up these sites is a scarce resource of high value for sustainable food production. The Government seeks to protect against the loss of such land from non-agricultural development and thus another reason why development is such locations is contrary to the guidance.

6. The same proposals were rejected by the Planning Inspector in 2017.
The Planning Inspector's 2017 response to the existing Local Plan for Warwick District states that there is a need "to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth". It also states that:
"Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area".
This area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt's contribution to the openness of the countryside, food production and biodiversity are stronger now than eight years ago when these comments were made.

7. Contribution to 'overarching principles' of the Local Plan.
SG06 contributes to two of the five 'overarching principles' of the Local Plan: 'healthy, safe and inclusive' and 'biodiverse and environmentally resilient' as follows:
i. A healthy, safe and inclusive South Warwickshire: In surveys residents say that the open Green Belt location is the thing they value most about living in this area, with benefits for both physical and mental health. Use of the public footpaths increased markedly during the Covid 19 pandemic lockdown and has continued since.
Area SG06 is distinctive green belt land because it is traversed by 3.2km of rural footpaths. Calculating this in terms of metres of footpath per hectare, shows that SG06 has a higher proportion of footpaths than the West Midlands Green Belt as a whole, which in turn is far higher than the national average.
Thus SG06 makes a direct contribution to the health and wellbeing of the thousands of people who use the area each year.
ii. A biodiverse and environmentally resilient South Warwickshire: A local study, carried out over the course of 2023-2024 has observed a diverse range of plant and wildlife in SG06. The hedgerows, field margins and managed meadows provide habitats for:
◦ roe deer, Reeves muntjac deer, badgers, rural foxes and otters
◦ birds on the RSPB 'red list' including skylarks, swifts, fieldfares, house sparrows and starlings
◦ birds of prey such as sparrowhawks, peregrine falcons, kestrels, buzzards and red kites
◦ butterflies, dragonflies and damselflies
◦ plants which are vital for conserving the wildlife chain, for example musk mallow, bush vetch and yellow archangel.
The high quality agricultural land continues to provide rural employment and undergo diversification of farming techniques. Its use for modern arable, grazing and wildlife refuge benefits the environment as well as helping to preserve the characteristics of a rural Victorian village in Old Milverton.