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Mod 14 Objections

Objection 1: Planning Inspectorate Instruction Correspondence Ref PIN/T3725/429/5 regarding Duty to Cooperate has not been met.
The engagement between the six different councils comprising the wider Coventry and Warwickshire Housing Market Area cannot be considered constructive. Specifically Warwick District Council and Coventry Council have not taken sufficient account of available and lower value Green Belt. Doing so would negate the need to remove Miverton from the Green Belt

Objection 2 A lack of consistent approach by Coventry City Council and Warwick District Council shows a lack of strategic cooperation
The Coventry Local Plan states
It should be clarified however that at the current time some of these sites are within the Coventry Green Belt and as such remain constrained by Green Belt policy until such time as the Local Plan is adopted. As such, these sites will not be considered readily available until such time as the land is removed from the Green Belt.
If WDC were to adopt a consistent approach with Coventry City Council then either Milverton would remain outside any consideration for removal from Green Belt, or Green Belt land within Coventry would be included and adopted into the Coventry Local Plan. In any event Milverton should be logically excluded from development if a consistent and cooperative approach were adopted.

The Joint Green Belt Study identifies Parcel RL1 (Milverton) as being of significantly higher value than other Green Belt land. More appropriate Green Belt land including BU3, BE1, BE4, BE5 and N6 in Nuneaton and Bedworth, C6 and LL2 in Rugby, KG3 in Warwick is identified by the JGB as being effectively 'infill' and would be well contained by existing significant features and the landscape.

Objection 3 Exceptional circumstances and planning conditions for developing the Green Belt at Milverton have not been met
As identified in Objection 1, the Coventry City Council has not taken into account available suitable Green Belt land when making its housing availability assessment. The Coventry City SLAA LP53 January 2016 identifies 29 different sites suitable for housing schemes greater than100 units which could provide 10,424 housing units in Coventry alone if taken into account. Considerable evidence exists to show that exceptional circumstances to remove Milverton from the Green Belt not been met and any attempt to do so would risk rejection of the modified Local Plan by the Planning Inspectorate.

Objection 4 Developing East Milverton is not consistent with NLP objective (4.12.4). help the public access and enjoy open spaces...reduce the risk of flooding; keep the effects of climate change (including the effects on habitats and wildlife) to a minimum, and support healthy lifestyles.

The Strategic Housing Land Availability Site Assessment for Leamington Part 1 identifies North Milverton (L07) is a Green Belt site of medium value. Other assessment referred to within the Landscape Character Assessment for Land South of Leamington and Warwick show the North Milverton Green Belt as being of high value, in contrast, for example, to part of the Blackdown site adjacent to Sandy Lane (referred to as WL6a/b in this document and shown to be of medium value). The Milverton site is enjoyed by a wide section of the community, it is an important asset in supporting healthy lifestyles for residents and visitors of all ages - whether it be walking, running or cycling. The public footpath that transverses the site provides a valuable access point from Leamington to the Warwickshire country side and should be protected.

There are strong grounds for environmental concern regarding proposed development of the site.
The Strategic Housing Land Availability Site Assessment for Leamington Part 1 identifies that:
* a part of the site falls within a flood zone 3A and implicitly should not be developed;
* it contains a Water Source Protection Zone and an area of Groundwater Vulnerability, which would require consultation with and permission from the Environment Agency before any encroaching development. We know from a past pollution incident from the Nuffield Hospital, and related correspondence, that the Environmental Agency view this Zone/area with extreme seriousness.
* it would result in the extensive loss of Grade 2 agricultural land which both contributes to a sustainable economy and to the character of the landscape.