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We understand that the National Planning Policy Framework requires that exceptional circumstances have to be established by Warwick District Council to remove the land North of Milverton from the Green Belt. This criteria has clearly not been established in a way that stands up to close examination.

The proposed development has been justified in order to support Coventry City Council's housing need. The foundation to these proposals is highly questionable. We understand that the Government stipulated that each local authority with planning powers had to make plans to build a certain number of homes. The number that each local authority had to plan for was prescribed by the Government. It is therefore surely reasonable to assume that the Government felt that the number of homes they expected to be planned, by each local authority, could be built within that council's boundaries. For a local authority to just pass on this requirement to a neighbouring authority, which also has its own Government target to reach, is unfair in the extreme.

Even if this passing on of some of Coventry's target for new homes to Warwick District Council is deemed the only way forward, then it can only make sense if these houses are built on the edge of Coventry and not on the edge of Leamington Spa. If these homes are destined for people currently living and working in Coventry, then it is only rational if they are as close to Coventry as possible to reduce unnecessary commuting, inevitable congestion and further road construction with the resulting environmental damage.

What kind of logic is it that says we have to provide for Coventry's housing needs by building those houses on the edge of Leamington Spa? It is a well-known fact that commuting is bad for the individual concerned and bad for the environment. This 'plan' would force people into making long commutes across the remaining green belt to their place of work,

When considering releasing land from the Green Belt, it has been established that the value of potential sites to the Green Belt must be taken into account and those with the least value prioritised for removal from the Green Belt. We understand that WDC and Coventry City Council have assessed sites on the edge of Coventry as being of lower Green Belt value than the Old Milverton site. It is therefore perverse, when there are sustainable sites closer to Coventry, that land north of Milverton should be first choice.

The whole rationale for the Green Belt was to protect "green lungs" between conurbations. The green lung between Leamington and Kenilworth would be reduced to less than 11/2 miles if this development was allowed, seriously undermining its value. The attractive and pleasant northern entry to the historic regency town of Royal Leamington Spa will be irretrievably damaged. Highly beneficial and productive land will be destroyed together with a well-established wild life habitat. The green belt also exists to protect the character of towns and cities and the character of Leamington Spa, with its Regency centre, is based on its being the size it is now and not to become a dormitory area for Coventry.

The residents of the wider Warwick District area will be deprived of an area which is highly valued and sustainable for all manner of pursuits, such as rambling, jogging, cycling, riding and bird watching. This proposal will be a disaster for Leamington Spa.

The park-and-ride scheme as proposed, is unsustainable because:
* There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable and face not being able to board buses which may be full at peak times.
* The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* Much of the traffic using the A452 is destined for the south of Leamington where the major employers are situated.
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington.
* Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
* There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding

A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.

In summary, we believe the land north of Milverton should remain in the Green Belt.
The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.