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I am emailing to register my OBJECTION to the proposed development in Old Milverton and Blackdown as set out in Warwick District Council's Preferred Options for the Local Plan.

Whereas I acknowledge that the District Council needs to have a plan for future development I have strong and valid objections for proposed development in the areas of Old Milverton and Blackdown, north to and on the edge of present boundaries of Leamington Spa in designated Green Belt land.

Please read through my points below:

Note:
Apologies if I sometimes refer to the Warwick District Council (wdc) as 'Council' - it is the people in charge of making decisions and who have the responsibility to listen to the views, concerns and objections of residents such as myself to whom I refer.
I know the term 'Green belt land' - but unsure about other - I think 'White land' is land identified for building potential but which is not designated Green belt - as I am unsure I have called such land 'not-green belt land'.

1) PROPOSED NUMBER OF HOMES:

Whereas I acknowledge that the District Council needs to have a plan for future development, I have strong objections for proposed development in the areas of old milverton and Blackdown, north to and on the edge of preasent boundaries of Leamington Spa in designated Green Belt land.

There appears to be an over-provision/over-calculation of proposed housing; most probably as the council have forecast using figures from periods of exceptional growth in the past. Such growth can not be assumed and therefore I would prefer that more realistic figures are applied.

WDC has added nearly 1400 homes to the number that it anticipates will be required so as to 'buffer' its proposals. There does not seem to be firm evidence about numbers of houses needed - and if figures are correct, why would there be a need to add on the 'buffer' of 1400 extra homes - a considerable percentage of the total of homes 'needed' in the WDC plans.

If this 'buffer' is removed from the WDC forecast then there would be NO NEED to include the land noth of Leamington in Old Milverton area and Blacvkdown.

Also, the non- green belt sites already identified by the WDC (and not all listed in the 'Preferred options' plan) for development could still possibly be built upon if the present owners get planning permission/sell to developers, etc - therfore reslting in even more excessive housing.

Change to plan: Remove the 'buffer' (approx. 1400 homes) which would easily allow removal of development plans on Green Belt
land in Old Milverton area and Blackdown.

2) OBJECTION TO DEVELOPMENT OF GREEN BELT LAND:

The government has made it clear that it holds great importance to Green Belts (e.g. in the National Planning Policy Framework - NPPF) and I am aware that Local Plans must adhere to NPPF principles.

One of the NPPF's goals is to protect communities and Green belt and to help local people "to protect local countryside and green space they value" ... I value the Green Belt land outside my front door - and that which I have enjoyed walking through and looking at for the 44 years I have lived in Leamington Spa. WDC has a responsibilty to be accountable to the NPPF with its policies and practice.

The fact that the New Local Plan 'Preferred Options' suggest development on Green Belt land is dreadful considering that there is other non-greenbelt land available on which the proposed number of houses/development could be built and local needs met.

The fundamental aim of Green Belt is to prevent urban sprawl by keeping land permanently open. That should be WDC's priority - to leave designated Green belt land as it is when other sites are avalable.


The Greenbelt in Old Milverton and Blackdown fulfills the the first 4 of the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land. It:
- Prevents the unrestricted sprawl of leamington to the North
- prevents the merging of leamington and Kenilworth
- helps to safeguard the countryside from encroachment
- helps preserve the setting and special character of Leamington (a historic spa town amidst beautiful countryside)
If other AVAILABLE non-Green Belt land is developed then the 5th purpose would also be addressed:
- Helps urban regeneration, by encouraging the recycling of derelict and other urban land
... Development of Green Belt land in Old Milverton and Balckdown would be contrary to the NPPF guidelines.

To build on Green Belt land North of Leamington Spa would result in a spread towards Kenilworth and put both towns at risk as the danger would then be that future Councils would encroach further and further across Greenbelt land and result in the towns joining together.

Proposals in the New Local Plan would reduce the "Green Gap" betweeen Leamington and Kenilworth to less than 1 1/2 miles; encouraging the merger of these two towns and their loss of independent identities. The village of Old Milverton would also be at risk of being swallowed up into Leamington and lost as an 'independent' village community.

There are many other non-greenbelt sites that could be developed instead - those areas should take priority above any Green Belt land. As a matter of principle and responsibility the Council needs to develop these non-greenbelt areas instead. Many of these sites, which were includede in warwick district council's previous plan (the 2009 Core Strategy), are south of Leamington Spa. (I will expand upon this issue in a later section).

The NPPF states that greenbelt boundries should only be altered in exceptional/ very special circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land. Therefore, WDC has not demonstrated the 'exceptional circumstances' correctly.

The Government's NPPF states that development of Greenbelt land should only be allowed if the benefits of development outweigh the harm caused to the Greenbelt. There is no evidence to show that development on Greenbelt land north of Leamington would provide sufficient benefits to the community and Greenbelt land. according to WDC the special circumstances are atht there is nowhere else for the homes to be built. However, as mentioned above, in the '2009 Core Strategy' (a plan which was adpopted by WDC) land south of Leamington (not greenbelt) was identified and IS STILL AVAILABLE for development.

If WDC applies a policy of spreading developments areound the edges of Leamington and Warwick on grounds that it will not cause as many objections from one local area/group of pouplation then that is not a valid 'planning policy' - or one acknowledged by the NPPF - it is more of a political move to please everyone. (Apologies if not termed correctly!) The WDC needs to only apply planning policy to this situation - therefore, build on non-Green Belt land first ... NOT leave non-green belt land 'vacant' and undeveloped and yet take away and develop valued Green Belt land.

The 2009 Core Strategy is sound basis as evidence that there are alternative areas for development other than Green Belt land north of Leamington - it also sustains that the "very special circumstances" put forward by the present WDC are wrong.

WDC had studied the value of Green Belt land north of Leamington (old Milverton and Blackdown) which concluded that these areas had HIGH GREEN BELT VALUE. Therefore, should not be built on.

Change to plan: Develop areas south of Leamington that have already been identified by WDC as apporpriate for development.
Erase any proposals to develop Green Belt land north of Leamington Spa.


3) HEALTH, LEISURE and WELL-BEING:

The land suggested for development in Old Milverton and Blackdown is used by many people - individuals, couples and families; and groups (such as, local scout groups) - for recreational purposes ... walking, dog walking, rambling, cycling, running, bird watching, etc.

Highly valued, cherished and utilised recreational areas need to be protected.

Health and well-being of Leamington Spa's residents is important.

These areas provide Leamington and Warwick residents with easy access to the countryside environment.

For example, the footpaths across Old Milverton (e.g. entered from Bamburgh Grove/allotment area down to Old Milverton and onto the Saxon Mill and beyond) are regularly used by local residents (such as, myself) and also people not from the local area who choose to walk in an area of beauty and tranquility. Having access to outdoor ammenities such as the pathways that cross the Green Belt land is an activity to be enjoyed by all ages; and definitiely an encouragemnet to keep young people busy and away from anti-social behaviour.

Any proposed development on the Green Belt land would encroach on this valuable local asset which encouirages people to visit our lovely town - an area and amenity of which residents and the WDC should be proud.

There is very little publicly open space in the north Leamington area - we need to protect that Green Belt land for future generations and visitors to enjoy.

There are many elderly and infirm residents around the Old Milverton and Blackdown areas - it worries me that developments surrounding their homes will have a harmful affect on their health and well-being caused by worry, stress, noise, light pollution, extra traffic, etc. which could be avoided if the Green belt land is not built upon. Many of our older, long-term Leamington residents will have been unable to lodge their objections with the consultation system having been advertised and completed in the way it is. (Many will not be able to access the internet, read easily, rely on carers, etc.)

To be fair to all of those in our communities - a door-to-door consultation/questionnaire should bge used to ascertain the opinions of all residents. A postal questionnaire could be carried out and then WDC employees call at houses not retur=ned a view/opinion.
Land that has been designated as Green Belt land - and so shown as such in 'searches' when people buy their homes - has had a key affect on people's decisions to purchase their home in present outer edges of Leamington that are earmarked as residential areas. That amenity and privilege is often reflected in house prices (more costly). Local residents have chosen to live where they do because of the positive aspects that living near Green Belt land without affecting the Green Belt land itself (that is, not buying houses built on and destroying designated Green Belt land). If nearby Green Belt land is developed that will have an adverse affect on local residents' enjoyment of their homes, and highly likely, their well-being; totally changing the landscape and area where they have chosen to live. The counil have a responsibility to their present population/rsidents - what is the point of having alegal system (e.g. searches) when the council can then change its boundaries?!! (excuse the pun!)

Change to plan: Omit Green Belt areas in Old Milverton and Blackdown from the Local Plan as they are valued areas for recreation
as the Council has a responsibility to provide areas for recreation - and protect those we already have AND USE!
Ensure that the consultation actually does 'consult' all residents - especially considering the elderly and infirm



4) WILDLIFE:

Any development of the Green Belt land in Old Milverton and Blackdown would obviously have a negative, detrimental effect on the environment and local woildlife - e.g. destroying habitats, increased noise and light pollution, pollution from traffic, etc.

The Green Belt land surounding Old Milverton, North Leamington, Blackdown, is beautiful and home to many varieties of plant, tree and creature.

I see many wild birds from my house and as I walk along the pathways crossing the Green Belt land; including a heron who regularly visits and flies over the field opposite my house. There are newts, etc that live on the land nearby - and woodpeckers nest in trees. Areas such as these are already few and should be protected.

Any development in this area of Old Milverton would have a dramatic and negative impact on the natural environment.

The WDC has a responsibilty to protect Green Belt land that homes such a wealth of wildilfe and plants. The Green Belt land should be a valued resource - not something that can be signed off to developers!

WDC also has a responsibilty to the education of all the young people within our community - without these Green Belt areas - and established pathways and habitats - children and young people will not be able to learn about and value our countryside and wildlife.


Even if proposed developments suggest areas for 'green space' they would be artificial and wildlife would have already 'moved on' when developments are being built.

Change to plan: Erase proposals to develop Green Belt land north of Leamington Spa.
Protect present Green Belt land & wildlife.
WDC should ensure they have a firm policy to only plan to develop non-Green belt land as there is enough of that
available to suit the anticipated growth and need of our community.

5) DEVELOPMENT SOUTH OF LEAMINGTON:

As referred to earlier, there are many sites to the south of Leamington Spa which have been identified as areas which could be developed and are NOT greenbelt land. therefore, these sites should take priority as it is important that Greenbelt land should be protected.

Assessments made by WDC (re. 2009 Core Strategy) identified the sites south of Leamington as land which is easier to develop than land to the north of the town, and the land south of Leamington already has a substantial amount of infrastruicture in place which would support further development and increased population. The Council had identified available land east of the A452 (Europa way) and south of Heathcote towards Bishops tachbrook - these areas are still appropriate sites for development and should be considered in full.

There is factual evidence from SHLAA that enough land exists south of Leamington spa for the development needs of WDC. So this should be built on before any Green belt land is destroyed.

Land south of leamington is close to the M40 and various link roads and the A46 - allowing easy access to roads and rouotes for residents and businesses south of Leamington.
There are existing employment opportunities south of Leamington.
Employment opportunities and infrastructure already exists south of Leamington.
Large shopping facilities (including, major supermarkets) are south of Leamington.
There has also been talk about development of another large supermarket near/on the old Ford foundary site, south of Leamington; the old Oak pub site, etc.

It would therefore, seem better to build more homes south of Leamington as they would have easier access to those shops and not (if developments north of town) cause more grid lock through the town centre, with people trying to get south town to do shopping (and travel to work, and links to M40, etc).

WDC suggests that the land south of Leamington is not as attractive to developers because of coinsideration of development in that area may result in the developers making less profit. May I propose that:
- Developer's financial gain should NOT be a priority (definitely not a "very special circumstance")
- Developer's financial gain is NOT a valid reason to allow development on Greenbelt land
- The financial investment of present leamington residents (e.g. money we have invested in purchasing our homes as they are) is
important - developments on greenbelt land in full view of many homes north of Leamington will affect the house prices of
present loyal local residents - WDC should protect local residents

As far as I am aware, due to the land layout, developments in south of leamington would not have such a visual impact as they would north of leamington - where developments would be more visual to both present local residents (views, lifetsyles, well-being affected) and visitors approaching our lovely town. Therefore, it makes more sense to develop south of Leamington where the developments can suit the land and area more suitably.

There are already good routes laid out for public transport south of leamington which serve the community well and would easily be enhanced if development happens in that area. The restructuring of public transport rourtes and ammenities north of Leamington would be costly, difficult and disruptive.

Change to plan:
WDC should adhere to their proposals from 2009 and make developments in areas south of Leamington Spa.
Prioritise development south of Leamington due to reasons listed above (e.g. present infrastructure, non-greenbelt land, employment and business amenities already in place, large open areas to develop communities which will develop positively)
Remove proposed Green Belt areas north of leamington from the 'Preferred options' plan.



6) PROPOSED NEW ROADS:

Turning the A452 between Leamington and Kenilworth into a dual carriageway will not help traffic flows. at peak times of the day the delays on the A452 result from commuters waiting to access the town centre. With developments north of leamington that will just add to the traffic.

Such a major road will have a detrimental affect on the visual approach to Leamington (and into kenilworth) - the rural aspect is something that people like about our town. To put in a dual carriageway and built up areas north of the town would make Leamington look just like 'urban sprawl' and not attract so many visitors/new residents.

Building hundreds (thousands) of houses north of Leamington willl increase the congestion into the town centre - at peak times and weekends - and also as people try to drive the 'short route' through Leamington town centre, down through town to get to the larger shopping areas (and ammenities - e.g. bowling, restaurants, pubs) south of Leamington.

Without the need to build vast amounts of houses north of Leamington (see earlier reasons) there would be no need for WDC to spend excessive amounts of money (i think budgeted at around £28m; so could be more eventually) in bulding a 'Northern Relief Road'. Residents from north Leamington travel south to south town - not out and around... new home owners would just be encouraged to travel out and away from Leamington and it's shops etc (eg to travel off to Coventry and Birmingham instead). without development in north Leamington the road would not be needed - saving WDC (and ratepayers) lots of money.

Should a 'Northern relief road' be considered it would form a further barrier across Green belt land; and encourage furure developments in Green Belt land as well, resulting in urban sprawl and merging together of Leamington and Kenilworth. It would have an adverse effect on the River Avon area; also valued for wildlife and recreation. The road would be incredibly and excessively costly as would have to be built on what is known to be a flood plain.

if the proposed development is concentrated in the south of Leamington spa then there is already an existing road network that could easily (less costly!) be upgraded to suit local needs. It would also be easier to sustain and enhance the good public transport links and routes south of the town rather than put n lots of new structures to the north.

Change to plan:
Erase proposals to develop Green Belt land north of Leamington Spa and so negate the need to build a 'Northern Relief Road' as detailed in Preferred Options Plan.
Plan to enhance public transport systems south of Leamington

7) PROPOSED OUT OF TOWN SHOPPING AREAS:

Where new out of town shops and stores have beeen proposed, this would have a detrimental affect on the independent retailers within Leamington (and probably kenilworth & Warwick) town centres.

Further 'out of town' shopping complexes will take shoppers out of towns where local, independent traders rely on customers; shops will close (even more than are empty already) and this will have a negative affect on our town - reducing the appeal of the town and the number of visting shoppers who like to visit Leamington for shopping.

A town of empty shops - and few independent retailers will not encourage people to come and live in Leamington Spa.

8) OTHER OPTIONS:

There seems to be a lack of detail in the available documentation about the other options available for development within the present town and residential boundaries.

There are many empty houses and buildings in Leamington which would surely be ripe for developers (and the council) to develop and rennovate. This would look after buildings in the town , helping the town to look better and - most importantly - providing affordable homes for our younger - and older - generations.

There are other places that 'we' hear whispers about being developed - have they been included in your 'preferred options' plans and oropsals? For example, the fire station ... Fords foundary area ... grounds form the old Park and Croft hall schools? all areas need to be fully adveryosed to the public in order for educated opinions to be logged.

Change to plan: WDC to look at developing more buildings and sites within the present residential areas and town centres -
provision especially for affordable housing.
WDC to readvertise where ALL possible sites for development are - not just 'preferred options'


9) OTHER CONCERNS:

The proposals don't seem to make it very clear about WDC projections for the impact of new developments on crime and anti-social behaviour figures. New developments will have an impact on present residential areas.

I object to the term used as 'Preferred Options' to the general public. having attended a council meeting earlier in the process it seems that there could have been a way of ensuring that all sites identified as having development potential could have been advertised more readily to the general public at this tage. this would have includied those poropsed and agreed in the 2009 proposals - those that have been ommitted (or at least not so obviously displayed) to the public gives them an unclear/uneducated view of all possibilities. ALL available sites should be made available for the general public to know about - and so make a more informed decision - including the non-green belt sites south of Leamington.

The proposed 40% affordable housing figure given in the WDC plan concerns me - as there seems to be no firm evidence why this wuld be the percentage of affordable homes needed. More consultation needs to be done on this. There has been no poll of local residents. If too much 'affordable housing' is built it may well stop people wantig to move to certain areas in and artound Leamington - and stop residents wanting to stay in Leamington long term. WDC has a responsibility to its long term residents.

Change to plan:
Investigations/research into impact on social issues, crime statistics etc. needed
WDC to readvertise where ALL possible sites for development are - not just 'preferred options'

CONCLUSION:

Finally, thank you for taking the time to read my lengthy email. As you can tell, i feel very strongly about the valid points I have raised and hope that 'you' (the district council) will reconsider your Preferred Options and NOT develop on the land north of Leamington in Old Milverton and Blackdown areas.

There are clearly areas available for development which would allow the council to meet the needs of the town and their responsibilities without building on such precious and Green Belt land. The WDC has NOT provided adequate evidence for 'very special circumstances' for suggesting Green belt land for future development.

In view of the need for some town growth, the general proposed numbers should also be reduced without the 'buffer' of 1400 homes which most probably won't be needed. This would also erase needs to build on the Green Belt land north of Leamington.