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I am writing to express my strongly held view that "The Local Plan Preferred Options"
document is not compatible with the Regional Spatial Strategy (RSS) for the West Midlands.
In particular I am objecting to the inclusion of the fields between Northumberland Road and
Old Milverton being included in the plan, for the reasons expressed below these must be
removed and if the housing is still required, then that housing should be located elsewhere
in the district.
When I examine the evidence base for your plan, and in particular the Strategic Housing
Land Availability Assessment I note that almost all the suggested rural areas are discounted
because they conflict with RSS policy point RR1. It is clear that overwhelming importance
has been placed on the policies in this document. This must be balanced with the important
policies expressed in the National Planning Policy Framework which rightly protect the vital
importance of greenbelt land.
However this RSS document includes policy QE14 that states that "Development plan
policies should create and enhance urban greenspace networks by ensuring adequate
protection is given to key features such as parks, footpaths and cycleways, rivervalleys,
canals and open spaces". It is not recorded in the Strategic Housing Assessment that a
footpath crosses the land between Northumberland Road and Old Milverton, but there is
most definitely one there, marked on OS maps, and heavily used as a local amenity to
people living in urban areas including Leamington Spa; this provides important health and
lifestyle benefits. In the Regional Spatial Strategy each policy is given equal standing and
therefore this policy is as important as RR1 which you have already used to discount so
much other possible development land. It only therefore stands to reason that this
greenbelt land too (as QE14 protects more than just the physical path, but also the green
land around it) should be removed from the preferred options plan. Indeed the proposed
sites L07 and even more so L03 are in my opinion some of the most highly used footpath
and recreational natural green space areas in the district and must be protected as such.
The suggestion of ignoring QE14 and building on the greenbelt, yet leaving the footpath is
logically unacceptable. The QE14 protects GREENSPACE, therefore there must be
GREENSPACE around the footpath. (This is essential to it's use). The policy identifies that
footpaths and parks are different and must both be protected. It is therefore unacceptable
to put the footpath into parkland as this is entirely different. The footpath and the
greenspace around it must be therefore be protected in their current form!
Furthermore the RSS also states in policy QE6 that; "Local authorities and other agencies, in
their plans, policies and proposals should conserve, enhance and, where necessary, restore
the quality, diversity and distinctiveness of landscape character throughout the Region's
urban and rural areas by: protecting and, where possible, enhancing natural, man-made and
historic features that contribute to the character of the landscape and townscape, and local
distinctiveness." The greenbelt to the North of Leamington is quite clearly a natural feature
of the landscape that contributes greatly to the character of North Leamington, Old
Milverton and the surrounding area, and is essential to the local distinctiveness of these
areas. This is clearly demonstrated in the huge number of signatures in petitions returned to
the Council surrounding the proposed construction on these areas.
Furthermore the protection of villages under RR1 is quite inconsistent; land is being used
incredibly close to Old Milverton for housing and particularly in the construction of the
Northern relief road. It is been ignored that Old Milverton should be protected by RR1:
"rural areas which are subject to strong influences from the MUAs and which are relatively
prosperous and have generally good access to services. For these, the main priority will be
to manage the rate and nature of further development to that which is required to meet
local needs, whilst ensuring that local character is protected and enhanced." It is clear that
Old Milverton is as strongly influenced as other Warwickshire villages from the key MUAs, it
is relatively prosperous and the residents are quite contented with their access to services.
Therefore just as development sites, for instance those neighbouring Radford Semele (and
still contacting the Leamington Fringe), have been rejected on the basis of RR1 so should the
developments between North Leamington and Old Milverton - neither these houses, nor
the relief road, nor the infill that would surely follow the construction of these two things
are meeting local needs, the character is certainly not protected nor enhanced.
In discussion with Daniel Robinson at Warwick District Council he informed us that the Old
Milverton to Northumberland road site is labelled as "an extension of urban land that
happens to come close to Old Milverton", not as a rural site in itself, this is not consistent
with sites eg R46 which is equally an extension of urban land that happens to come close to
Radford Semele but is protected by policy RR1 in the RSS document. These inconsistencies
persist throughout the SHLAA.
A final point I would like to make is that development on the land between Northumberland
road and Old Milverton is Green-belt land, which under the National Planning Policy
Framework should not be built upon unless exceptional circumstances exist. I personally do
not believe exceptional circumstances exist; for among other things because the 2009 Core
Strategy plan for the region did not involve development on this land, the fact that a £28
million relief road would be needed to make that land accessible, and that other land in the
South is identified as suitable for development with less investment required than here to
correct shortcomings. Therefore for this national policy reason in addition to the reasons
stated under the RSSthis land between Northumberland Road/Bamburgh Grove and Old
Milverton should not be developed. Furthermore if such arguments are not sufficient then I
firmly believe that the RSSbeing a regional policy document should not prevent some
additional development in rural areas not in the green belt (and despite RR1) as this too
does not warrant exceptional circumstances to allow construction in the green belt (a
national policy). Indeed as 38% of the district population live in rural areas, yet only 10% of
the development is located within rural areas then there is a strong argument that these
areas are not meeting their local need for housing.
In conclusion the location of the Leamington to Old Milverton footpath must be included in
the consultation and Strategic Housing Assessment. The New Local Plan is not consistent
with the Regional Spatial Strategy for the West Midlands, due to policies RR1, QE6 and
QE14, as well as the National Planning Policy Framework. For these reasons no land to the
North of Northumberland Road and South of Old Milverton should be used as this would
appear to demonstrate both cherry-picking and double-standards when it comes to the
decision making process of the council, and result in the plans being rejected by the
National Inspectorate.