Testun llawn:
We would like to raise objections to the proposed development Plan for North Leamington as detailed.
It is very clear that an enormous amount of work has gone into this draft. Nevertheless, it is seriously flawed and it does not reflect the views of the district residents, who, in the published surveys, advocate only modest development.
Points to Consider:
The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt and for the harm created to the Green Belt to be outweighed by the benefit of the development. Those special circumstances are apparently that there is nowhere else for the homes to be built. In the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land South of Leamington was identified, and is still available, for development. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure to support it. It is close to the M40 and there are existing employment opportunities South of Leamington.
The previous plan is direct evidence that there are alternative areas for development other than the Green Belt. Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because the concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt.
The proposals ignore Warwick District Council's Green Belt Study of the land at Old Milverton and Black Down which concluded that these areas had high Green Belt value.
Green Belt land is specifically set aside to prevent urban sprawl, stop towns merging together and protect the country side setting of historic towns. The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1/2 miles encouraging the merger of these two towns and their loss of independent identities. Turning the A452 between Leamington and Kenilworth in to dual carriage way will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centres.
The proposals will have a detrimental effect on the picturesque northern gateways to Leamington and Kenilworth. A "Northern Relief Road" (budgeted cost £28m) is not required. The traffic flows tend to be north; south rather than east; west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns.
A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.
The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area attractive places to live. Further "out of town" shopping will take trade away from the Towns.
The justification appears to be based on an assumption that there will be a substantial growth in population.
This country is already overcrowded and cannot afford the growth predicated.
There is a fast developing global food crisis. Britain will have to become more food self-sufficient, which means preserving prime agricultural land, even if the local population does grow at your forecast rate of 13%, it is unnecessary to plan housing at the rate of less than 2 persons per property!
There will be a loss of a significant amount of high quality agricultural land in Black Down and Old Milverton The land at Old Milverton & Blackdown has substantial amenity value and is presently enjoyed by a great many walkers, runner, riders, and cyclists. It provides a countryside environment close to the centres of Leamington and Warwick. Both the proposed building development and the "Northern Relief Road" would
substantially reduce the amount of land that is available to enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park would detract from rather than enhance its value.
I propose that the Council develops an alternative strategy, which is properly based on the following key elements of the NPPF. The current draft does not follow the NPPF.
1 Promote competitive town centre environments
2 Promote vitality of urban areas
3 Protect green belts around them
4 Recognise the benefits of best agricultural land
5 Conserve landscape and scenic beauty
6 Use brown field sites first
7 Only change green belt boundaries under exceptional circumstances
8 Even then, only consider limited infilling of green belt land
9 Avoid potential coalescence
I propose the plan be based on the following principles:
1 Accept that this area is already overpopulated.
2 Regenerate urban areas. Much of the housing is decrepit and should be redeveloped with a higher urban population density.
3 Regenerate town centres and depressed urban areas. Replace old housing with modern accommodation.
4 Accept that maximising economic growth and housing is NOT the priority for Warwick District.
5 Quality of life and the environment are more important.
6 Moderate developments is the key.
7 Existing green belt boundaries are sacrosanct.
8 Warwick District Council has included a "buffer" of 1400 homes in the number of houses that it believes will be necessary between now and 2026. If this "buffer" is removed from the assumptions there is no need to include the land at Old Milverton and Black Down in the proposals.
The plan should be developed strictly within these parameters.
If this means a slower rate of economic development, then that is appropriate for this District.
If this means a slower rate of population growth and housing, then so be it.
It is still possible to encourage new business, reduce unemployment and provide more housing, given a moderate development strategy.
Green belt boundaries are sacrosanct in this 'Green and Pleasant Land and we urge Warwick District council to consider the overwhelming number of objections to the proposed developments and concentrate efforts and funds into the development of the current infrastructure and development of current building opportunities to regenerate our Town centres.