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I am writing again having attended the public meeting at Old Milverton St James's Church.
I would like to thank Mr Bill Hunt for his clear explanation of the current position with the Local Plan Preferred Options. Even though he was unable to satisfactorily answer most of the key questions, he was respectful to the public views and attempted to explain the Council's position.
He was unable to explain what has changed since the extensive 2009-2010 Core Strategy studies and this is a basic requirement as set out in the NPPF:
The NPPF requires that if the Council is considering any changes to the Green Belt boundary, that it sets out whether any major changes have made the adoption of this exceptional measure necessary (para 82).
The Core Strategy had identified over 11,000 housing sites without infringing upon the Green Belt. The new preferred option has over 40% of the required 8,500 housing sites in the Green Belt.
He suggested that the three main gas pipes identified crossing one site was a change (it is unbelievable that this was not discovered during the earlier studies); he considered that the additional infrastructure required to develop sites south of Leamington would be slower to implement than those needed north of Leamington ( this is obviously inaccurate): and he suggested that one large site was harder to market than numerous sites ( the 2009-10 proposals included a good number of sites that were at some distance from each other).
These arguments do not stand up and a Public Enquiry will dismiss them as not being exceptional enough to overturn the Green Belt policies. Please see the conclusions of the recent Cheltenham Green Belt Public Enquiry - the first to have been based on the new NPPF policies.
He was unable to explain why the 2010 Joint Council (including Warwick DC) study of the Green Belt fringes was ignored.
The largest site proposed for development north of Leamington was identified in your own recent study as an absolute priority to remain in the Green Belt for protection.
When questioned on the costs and practicality of the Northern Relief Road, he suggested that it was not essential even if the development sites in the Green Belt went forward.
This may be true, but the Green Belt development will be certain to have a dramatic impact at the right-angled bend at the village green in Old Milverton, and on the two 'pinch-points' on the Stoneleigh Road - the top of the hill in Blackdown village where the width, bend and site lines make it a hazard for speeding traffic; and the historic old bridge in Stoneleigh which is unable to cope with any additional traffic being loaded onto this route. I do not think the full implications of these costs have been considered in your site evaluation.
The range of studies which have been presented to justify the Local Plan proposals are extensive but unsatisfactory in their findings. Two examples are:
The Strategic Housing Land Availability Assessment (May 2012) studies are particularly unsatisfactory as they present a very limited analysis of each site with no attempt to evaluate the implications or comparisons or costs of each measure. No infrastructure, social or environmental costs for the development of each site have been estimated. How is it possible to evaluate or compare sites if these considerations are not assessed? It seems that all sites assessed have been included in the Local Plan - there is no reassessment of the many other sites selected as part of the 2009-10 Core Strategy. There are no site options to be considered. This is certainly one of the poorest UK examples of urban growth site assessments in recent years.
The Garden Towns, Villages and Suburbs prospectus (May 2012) promotes the concept of sustainable development but fails to provide any new thinking on layouts, adaption to micro landscapes and environments, or how to accommodate large numbers of social housing. There has been no attempt to consider who pays the extra capital and on-going management and maintenance costs for the proposed additional public facilities - at a time when we are cutting back on public expenditurecould they even be included? Even though the document is well illustrated, showing huge numbers of trees, it provides a poor model for sensitive landscapes and boundaries with existing communities.
With the inability of Council officers to explain the reasons for these flawed proposals and the poor quality of some of the documents presented to justify the Local Plan, we can be certain the a Public Enquiry will require dramatic changes.
How will the Council be reflecting the views and recommendations resulting from this 'consultation' process?

04 July 2012

Development Policy Manager,
Warwick District Council,
Riverside House,
Milverton Hill,
Leamington Spa, CV32 5QH.


Dear Sirs,
Re: Warwick District Council Local Plan Preferred Options

I am writing to object to the proposals set out in the WDC Local Plan Preferred Options May 2012 document.

In particular, I object to your proposals for potential development in the Green Belt north of Leamington and Warwick.

1. Over the last 60 years the Green Belt policies have been one of the most successful and beneficial planning policies implemented in England, and it should be defended to avoid any weakening of this guidance.

The National Planning Policy Framework 2012 is very clear on this matter and even its definition of 'any exceptional circumstances', where Green Belt designation can be reconsidered, do not cover the conditions proposed for the Warwick District Council area.

2. The NPPF identifies five purposes (para 18) -
to check sprawl; to prevent neighbouring towns from merging; to safeguard the countryside from encroachment; to preserve the setting and special character of historic towns; and to assist urban regeneration by encouraging development elsewhere.
The WDC Local Plan Preferred Options for developing the Green Belt north of Leamington/Warwick, do not assist the achievement of any of these purposes.
3. The NPPF requires that if the Council is considering any changes to the Green Belt boundary, that it sets out whether any major changes have made the adoption of this exceptional measure necessary (para 82).
WDC has not identified any 'major changes' that have occurred since the Local Development Framework Core Strategy studies 2009/10.

4. WDC repeats that both the Strategic Housing Land Availability Assessment (May 2012) and the Joint Green Belt Study (January 2009) with other non site specific documents have guided the selection of sites. There is no explanation why all the sites that WDC identified after detailed studies for the Core Strategy were not included.
The SHLAA is a limited appraisal as there has been no attempt to comparatively value the different measures, and it does not consider the likely additional site related costs - infrastructure (roads and utilities), the wider impact on the local community, or the Green Belt considerations. The SHLAA is only a site by site appraisal and there is also no full explanation as to how these assessments have guided the selection of the strategy. One wonders how objective this appraisal is, as half the partnership team were either developers or their agents with interests in particular sites.
The Joint Green Belt study is likely to be more objective, but in some cases its findings have been ignored. Again this was not a site selection study for the growth of Leamington/Warwick as it did not consider non-Green Belt land. All it was able to suggest was that some sites could be reconsidered in comparison with non Green Belt sites, and that other parts of the Green Belt should in no circumstances be considered for development.

As a result WDC have selected sites in the Green Belt without fully reviewing all the non Green Belt sites, from a limited and very selective site appraisal, and have ignored the findings of their own extensive studies for the Local Framework Core Studies and the combined local authority Joint Green Belt study.
The Local Plan Preferred Options document only provides rate of growth options and does not provide the opportunity to consider any locational options or alternatives to development in the Green Belt.

I also object to the recommended road projects to the north of Leamington/Warwick that have been identified as preferred options.
The road proposals include the 'Northern Relief Road', a widened route from the Jet roundabout in Kenilworth along the Kenilworth Road to the Lillington Avenue junction in Leamington; a widened route from the Blackdown roundabout to the Bericote Road roundabout along the Stoneleigh Road; and a Park and Ride area near the Sandy Lane/Kenilworth Road roundabout.
The additional traffic flow calculations and assumptions (Warwick District Council Strategic Transport Assessment Modelling April 2012) - which could be questioned, are based on the assumption that the Green Belt development proposals are fully implemented, though the massive costs of this road infrastructure have not been considered as part of the site appraisals.

1. The alignment of the Stoneleigh Road is completely unsuitable for upgrading because of its physical conditions and constraints and any attempt would destroy the Blackdown community - further costs you have not included in your sites appraisal.

2. The so-called 'Northern Relief Road' would only benefit a small percentage of car users in this area and could not be much of an alternative route for traffic between Leamington and Warwick as it repeats the A46 route and would be unlikely to take any traffic away from the Emscote Road.

3. The proposed 'Northern Relief Road' will be a major cost - capital, environmental and social. Taking this road down the hill to the north of Old Miverton, across the flood plain and river, and creating a new junction onto the already multiple A46 junction, will be a frightening cost to load on such a short length of road and has to be added to the site development costs - as it is not needed otherwise. The environmental impact will be dramatic and the effect on the Old Milverton community will be unacceptable. A major impact could also occur at the old bridge in Stoneleigh - has this cost been considered?

4. Widening the road from Kenilworth into Leamington is an unnecessary cost and an environmental disaster - consider the trees, farmland and front gardens that would be lost. Widening roads can speed-up traffic, but it does not resolve congestion. Any congestion at morning peaks on the Kenilworth Road into Leamington is a result of the junctions, lights and pinchpoints from Lillington Avenue southwards.

I consider that development in the Green Belt to the north of Leamington/Warwick on the 'preferred sites' will have an adverse impact on the town centre economy - both the shopping centre and the attractions for heritage tourism.


1. Proposals for significant shopping in a newly developed area north of Leamington will have an adverse impact on the Leamington and Warwick town centre shopping economies.

2. Even with new employment land identified, there will still be a need for a significant percentage of potential new 'Northern' residents to travel across the town centre to the current and proposed major employment areas to the south of Leamington/Warwick. This will lead to increased town centre traffic congestion and make it a less pleasant place to visit.

3. Tourists and visitors wishing to enjoy the attractions and heritage of Leamington town centre currently can approach from the north through countryside (Green Belt) and an attractive tree lined road before passing the white eighteenth and nineteenth century buildings on the Kenilworth Road. The whole positive experience would be lost if the proposals proceed for housing, employment areas, park and ride and road widening removing many trees along this route.
4. WDC have stated in the Preferred Options document (page 17) that "many felt that increasing sprawl around the existing towns would damage the rural setting of the towns to the detriment of both their economies and their environment." This obviously would be a particular concern if development of the Green Belt occurred to the north of Leamington/Warwick.


I will be grateful if you would respond to these concerns as soon as possible. In particular, to explain what are the major circumstances that have changed since the long preparation of the Local Development Framework Core Strategy in 2009/10, and why you have chosen to ignore some of the findings of this Core Strategy and the Joint Green Belt Study 2009.































Hill House
Stoneleigh Road
Blackdown
Leamington Spa
CV32 6QR

18 July 2012

Development Policy Manager,
Warwick District Council,
Riverside House,
Milverton Hill,
Leamington Spa, CV32 5QH.

Dear Sirs,
Re: Warwick District Council Local Plan Preferred Options

I am writing again having attended the public meeting at Old Milverton St James's Church.
I would like to thank Mr Bill Hunt for his clear explanation of the current position with the Local Plan Preferred Options. Even though he was unable to satisfactorily answer most of the key questions, he was respectful to the public views and attempted to explain the Council's position.
He was unable to explain what has changed since the extensive 2009-2010 Core Strategy studies and this is a basic requirement as set out in the NPPF:
The NPPF requires that if the Council is considering any changes to the Green Belt boundary, that it sets out whether any major changes have made the adoption of this exceptional measure necessary (para 82).
The Core Strategy had identified over 11,000 housing sites without infringing upon the Green Belt. The new preferred option has over 40% of the required 8,500 housing sites in the Green Belt.
He suggested that the three main gas pipes identified crossing one site was a change (it is unbelievable that this was not discovered during the earlier studies); he considered that the additional infrastructure required to develop sites south of Leamington would be slower to implement than those needed north of Leamington ( this is obviously inaccurate): and he suggested that one large site was harder to market than numerous sites ( the 2009-10 proposals included a good number of sites that were at some distance from each other).
These arguments do not stand up and a Public Enquiry will dismiss them as not being exceptional enough to overturn the Green Belt policies. Please see the conclusions of the recent Cheltenham Green Belt Public Enquiry - the first to have been based on the new NPPF policies.
He was unable to explain why the 2010 Joint Council (including Warwick DC) study of the Green Belt fringes was ignored.
The largest site proposed for development north of Leamington was identified in your own recent study as a priority to remain in the Green Belt for protection.
When questioned on the costs and practicality of the Northern Relief Road, he suggested that it was not essential even if the development sites in the Green Belt went forward.
This may be true, but the Green Belt development will be certain to have a dramatic impact at the right-angled bend at the village green in Old Milverton, and on the two 'pinch-points' on the Stoneleigh Road - the top of the hill in Blackdown village where the width, bend and site lines make it a hazard for speeding traffic; and the historic old bridge in Stoneleigh which is unable to cope with any additional traffic being loaded onto this route. I do not think the full implications of these costs have been considered in your site evaluation.
The range of studies which have been presented to justify the Local Plan proposals are extensive but unsatisfactory in their findings. Two examples are:
The Strategic Housing Land Availability Assessment (May 2012) studies are particularly unsatisfactory as they present a very limited analysis of each site with no attempt to evaluate the implications or comparisons or costs of each measure. No infrastructure, social or environmental costs for the development of each site have been estimated. How is it possible to evaluate or compare sites if these considerations are not assessed? It seems that all sites assessed have been included in the Local Plan - there is no reassessment of the many other sites selected as part of the 2009-10 Core Strategy. There are no site options to be considered. This is certainly one of the poorest UK examples of urban growth site assessments in recent years.
The Garden Towns, Villages and Suburbs prospectus (May 2012) promotes the concept of sustainable development but fails to provide any new thinking on layouts, adaption to micro landscapes and environments, or how to accommodate large numbers of social housing. There has been no attempt to consider who pays the extra capital and on-going management and maintenance costs for the proposed additional public facilities - at a time when we are cutting back on public expenditure. Even though the document is well illustrated, showing huge numbers of trees, it provides a poor model for sensitive landscapes and boundaries with existing communities.
With the inability of Council officers to explain the reasons for these flawed proposals and the poor quality of some of the documents presented to justify the Local Plan, we can be certain the a Public Enquiry will require dramatic changes.
How will the Council be reflecting the views and recommendations resulting from this 'consultation' process?