Testun llawn:
I am writing to express by serious and deep-felt objections to the preferred options plan as part of the consultation process that ends on the 27th July. In particular I object to construction on the greenbelt land to the North of Leamington, particularly the area North of Northumberland road, and South of Old Milverton, which seems to be being referred to as "Milverton Gardens." I propose that there are sound and sensible planning reasons not to build on this land, and viable alternatives elsewhere. To build on this land would be to fail to "protect for future generations" an essential part of the National Planning Policy Framework.
SECTION 1: INCORRECT PLAN TO BUILD ON GREENBELT LAND
Development unsuitable on Greenbelt land:
The part of the plan that I am quite simply outraged about is the destruction of valuable greenbelt land. This is not in accordance with national planning policy, for National Planning Policy Framework identifies that greenbelt land should only be built on in exceptional circumstances. The plan the council has put together does not demonstrate exceptional circumstances, not do I believe are there exceptional circumstances within the county for this to be validated (it would be unacceptable for the council to simply take this consultation and find some more evidence that they argue makes greenbelt use warranted, the point of consultation is not to argue with it, but to find out and accept local views). No evidence has been cited by the council explaining the exceptional circumstances, and as this is an evidence based consultation this is unacceptable and the plan to build on greenbelt land must be removed. This is further compounded by the fact that development is proposed also on the South edge of Kenilworth increasing the risk of sprawl as the two towns are being moved closer together. There is already significant established sprawl between Leamington and Warwick, to allow future sprawl risking coalescence with Kenilworth would destroy the local area, the community and result in people not wishing to move to the area and thus prove unsustainable.
Arguments that the need for housing in the area warrant construction on the greenbelt as an exceptional circumstance are false; this is demonstrated by strong evidence for in Cheltenham (a region which like Leamington has a strong need for housing and a large proportion of the county covered by greenbelt land), here the NATIONAL planning inspectorate ruled that these were not sufficiently exceptional circumstances to building on greenbelt land, and it is only right that Warwick District Council take heed of this evidence in their plan and remove the greenbelt from their plans. It has been argued that 80% of the county's land is greenbelt, however this is a misleading statistic for in fact a far smaller percentage of the rural-urban fringe is protected by greenbelt land. It is therefore totally unacceptable to use greenbelt land to build 44% of the housing required under the plan. Furthermore the % of greenbelt bordering the rural urban fringe is there to prevent urban sprawl, this is a nationally stated policy, it is my opinion that building on the greenbelt to the North of Leamington risks sprawl with Kenilworth and Coventry (this is indisputable as an original purpose of the greenbelt is to prevent sprawl with these areas, nothing has changed with regard to these areas, so building on the greenbelt encourages sprawl).
Use of greenbelt land is also unacceptable for there are other suitable areas for housing to be built, which are outlined later in this letter. Early in the consultation process the council discussed the need to "spread the pain" around the county, and for this reason there was construction on the greenbelt. This is not a planning reason for building on the greenbelt and certainly not an exceptional circumstance; as this was mentioned by council members early in the consultation it is only logical this is the logic for construction on the greenbelt land. This logic is unsound and the greenbelt should be removed from the plans. Creating alternative arguments later to counter residents objections that "spreading the pain" or as you have referred to it as in your preferred policy document "spreading development around the district" is not in-keeping with the process of consultation, for this is arguing with the publics views gathered consultation rather than being guided by them.
It is important to note that the National Planning Policy Framework sets out five purposes for Greenbelt land. In summary these are; to prevent urban sprawl of built up areas, to prevent neighbouring towns merging, to protect the country side from encroachment, to preserve the setting and special character of historic towns, and to assist urban regeneration by encouraging the recycling of urban land. Given that the greenbelt land to the North of Leamington Spa and South of Old Milverton fulfils the first 4, and arguable also ensures the 5th of these objectives, this is quite clearly greenbelt of very great importance and therefore its development would be contrary to the National Planning Policy Framework and common sense.
I believe the council have been disingenuous, or certainly at least short sighted in their plans. The land to the North of Northumberland Road that is planned for development leaves no distinct boundary to the greenbelt, particularly to the West of the site. This is in contravention of the NPPF, but would inevitably result in further development of the greenbelt land beyond that currently mapped by the council. This site therefore is inappropriate for development for once the boundary of the greenbelt is breached in this location and housing built upon it, this will create a "slippery slope" of further greenbelt development; a disaster to the region and totally unwanted by residents.
Advantages of focusing building in the South:
I am a young person (23) returning to Leamington Spa to work, the access to rural space and greenbelt land are essential to me choosing in this area to live. These rural spaces and areas of greenbelt are essential to the heritage and character of our town. It is essential we preserve this to encourage future skilled people to live here. However I cannot afford to purchase a house in the area, rather I am forced to live with my parents. As a resident of the area looking to purchase a house I am strongly opposed to construction on the greenbelt land to the North of Leamington, rather I would prefer extensive construction to the South. Housing in North Leamington has always been, and no doubt will continue to be more expensive, this is why developers want to build there (as stated by a senior officer of the council) as developers can then sell the houses for more profit. We are desperately in need of new affordable housing, as stated in your plan, so not only is construction in the greenbelt not warranted as an "exceptional circumstance" but actually contrary to what the district so desperately needs! Allowing more construction in one area (the South) would increase supply and therefore decrease demand for houses there, and with increased supply and decreased demand it is a simple economic argument that housing would be cheaper in that area. A key part of your plan is to ensure affordable housing is available and therefore by persisting with construction on greenbelt land to the North of the Town you fail to provide an adequate and sustainable supply of affordable housing. Again your policy of "spreading development around the district" is not only not based on planning principles and harmful to the district, but in fact prevents you achieving the large stock of affordable housing, which you set out to do.
In the Milvertion Parish Council meeting I attended a senior officer of the council stated that putting all housing in the South would be "more than the market could bare," quite simply this is argument is not valid for justifying construction in the North Leamington Greenbelt. If the market cannot support that level of housing then clearly there is no need to build any more housing in the district for there is no more demand!
Furthermore focusing housing in the South would allow financial saving for the council; this is important in a time of recession with an uncertain future; it is the councils responsibility to spend taxpayers money as effectively as possible and by focusing construction in the South rather than "spreading" development around the town, then the council could benefit from economies of scale whereby new schools and other services could be built singuarly in one area rather than having to spread service provision at increased cost around the county. This would thus allow the council to benefit from an economy of scale.
Health Grounds
As a medically qualified doctor with a special interest in diabetes and obesity I believe it is vital that the council and planners take on-board that Warwickshire is set within the West Midlands, which exhibits the highest rate of obesity in England. Such an epidemiological problem is of tremendous importance to the health, wealth, sustainability and enjoyment of futures generations. The greenbelt land to the North of the Town has an incredibly important exercise resource; the footpath between Leamington and Old Milverton and on to Warwick. I believe this must be one of the most popular footpaths in the region and provides vital exercise and leisure benefits for the local population who walk, cycle, ride horses, jog on it. Destruction of this greenbelt would prevent people using this footpath ( being realistic very few people would use a footpath that runs through the centre of a housing development, even if it is a "garden" one, and this goes for arguments of putting it in a belt of parkland, which also would not give any benefit to the community, and as in many areas can result in foci for crime.
Attempts to recreate this leisure resource would not I believe be successful in a garden town; the footpath is free of charge to use, requires no special equipment to use, is open whenever local residents want to use it (even at night), can accommodate a high volume of people, can be used by those of any age (indeed people who grow up using it as children are likely to continue to use it as adults thus bridging a vital gap in ensuring exercise throughout life), it can be used individually or in groups. It also provides a low resistance, low impact, long duration form of exercise that is vital to older people needing to exercise. It is my opinion that even a combination of play areas, sports grounds, parks and facilities would fail to fulfil these criteria. When canvassing opinions from people using the greenbelt we were amazed at how widely people come from across Leamington to use this resource - it is a benefit for the whole town, and indeed the whole region - this letter, and the strong opposition to the greenbelt destruction cannot be accused of being "NIMBY (Not in My Back Yard). Ensuring the health of the population of Leamington is vital to creating a sustainable development plan, building on this vital local resource fails to meet the needs of today's population but also destroys a vital amenity for our future increasing the risk of heart disease, diabetes, stroke etc and increasing the burden on our health services. Building on the other sites suggested in this letter avoids such problems.
It is of particular importance to myself and local residents to note that the area of highest use, accessibility and therefore greatest amenity and health benefits are the fields closet to Leamington Spa, therefore even the smallest amount of encroachment into the greenbelt would be unacceptable and harmful to the community and it's future sustainability and this is not what the very strong opposition to your plans from local residents have asked for.
The area between Kenilworth and Leamington Spa is subject to air quality management measures due to the high pollution created by surrounding pre-existing infrastructure, not only would new roads create increased levels of air pollution (harmful to the population, and in particular those with respiratory diseases eg asthma) but also the proposed development would reduce the Green Lung between Leamington and Kenilworth to less than 1.5miles reducing the ability of this land to absorb and decrease surrounding levels of air pollution. It is hardly sustainable to future generations to encourage harmful levels of pollutants in the air and therefore building here fails to achieve the plans aims for another reason. The land to the South of the town, does not suffer from the risk of coalescence with other towns, and indeed areas to the East and West not subject to air quality management, and thus would provide far better locations for the construction of new developments.
Wildlife Value
There is considerable wildlife and conservation benefit to the greenbelt between North Leamington and Old Milverton; it is essential we preserve diversity of wildlife for future generations, and this is intrinsic to a sustainable plan. Protected wildlife in the area includes; bats and their flight-paths, gliss gliss mice, great crested newts and badgers and their sets. This is without any study and I'm confident that careful study would elucidate other important species, this is likely to produce significant delays with biodiversity study, and protest questioning the ability of the council to deliver the site in an appropriate timescale if at all. I and many like me believe that we and Warwick District Council have a duty to protect these creatures, attempts to move them are unacceptable.
Employment
The preferred option plan's suggestion of construction of housing in the North Leamington Greenbelt fails to take into account the employment landscape of the district past, present and in future. Myself and other residents have strong objections and concerns that there will not be enough employment in North Leamington. This is a further reason that construction should not occur on the greenbelt. Whilst the plan suggests that some land will be made available for employment there is no thought as to what, where, or who this might be. There is no consideration as to why employers would consider not locating in the South where there is far better access to the M40 and national infrastructure (even with the proposed trunk road) nor why they would leave an area where there is already both competitors and suppliers, both of whom would make South Leamington more attractive. I believe that the only employment you could be confident of having in the North would be employment to service those who live in the new houses there, this would no doubt involve out of town shopping and further damage the centre of Leamington Spa, disastrous for the local economy at. Furthermore there is NO EVIDENCE provided whatsoever as to whether and if so which employers would locate in the North. The vast amount of employment and retail land in the South provides an abundance of EVIDENCE that employers are not only there, but also want to be there and new development/employers continue to locate. You have failed in your consultation document to demonstrate evidence of successful employment opportunities deliverable to the North and as a consequence myself and local residents do not want construction in the North, again this is not an invitation to attempt to justify your decision to put housing in the North, but rather listen to resident's views and act on them by not building in the North.
Housing in the North poses a very serious risk that people would need to commute to South Leamington to work, or alternatively to the M40 both these would involve travelling across the river at peak times when congestion is already unacceptable, this would hardly be sustainable and contribute to air pollution which has already shown to be excessive in the North.
At the Milverton Parish Council meeting it was proposed that the construction of the Coventry Gateway/airport project(s) would provide employment for those living in the North. This is unacceptable for two reasons; the first is that this is construction on greenbelt land seemingly justifying more development on greenbelt land - this is of course poor reasoning for justifying exceptional circumstances for construction on the greenbelt land! Furthermore this employment land abuts and provides significant benefit to Coventry; I do not believe Warwick district should be responsible for providing housing in Leamington for employment that is effectively in Coventry regardless of where historic district borders are drawn, nor will the planning inspectorate. If this land is exceptionally required from the greenbelt to provide housing for employment, that land should be provided near Coventry. Furthermore having people living in North Leamington yet working in Coventry risks turning Leamington into a commuter town - with great disadvantages for our town centre, and those who work there. Finally there is considerable congestion around peak times in journeying to Coventry, the infrastructure is not in place to allow people to commute to Coventry and indeed any improvements that were made have simply begun to tackle the current problems. These highways agency solutions have hardly corrected the problems that currently exist for significant congestion remains at peak times For all these reasons construction on the greenbelt in the North is incorrect and an alternatives strategy should be sought.
This plan goes against almost a century of town planning in Leamington; the 1943 Royal Leamington Spa plan for development identified that employment land had already been focused in the South of the Town, and highlighted the importance of continuing this development this further. Vitally this was seen (and has continued to be seen) as the correct policy when the M40 did not exist, the presence of the M40 only strengthens the desire for business to locate in the South of the town, and therefore it is essential housing locates close to this to prevent further congestion in the town. The 1943 plan further elucidates that construction of housing in the North would serve simply as commuter accommodation for those working in Coventry. The local residents do not want Leamington to develop into a commuter town, nor the demise of the town centre that would result from this, this is a further strong argument for not building on the North Leamington Greenbelt. These are hardly pithy historical notes, but instead provide a firm evidence base tested over 60+ years demonstrating successful location of employment land in the South of the town, and the risks of commuter accommodation in the North. The council have totally failed to provide strong evidence for employment to locate to the North, nor for this to function as successful housing for the town, indeed at the Milverton Parish Council meeting the Deputy CEO couldn't give any significant detail as to what sort of employment would locate to the North. I must repeat again that this letter is not an invitation for the council to now seek this evidence or contest these arguments (supported by petitions, other letters, and record breaking meeting attendance), but to listen to local views and use them to modify their plans to remove construction on the North Leamington Greenbelt - to fail to do this would be to fail to consult properly.
To be sustainable housing should be planned close to proposed employment otherwise it will have adverse impacts on commuting and travel. If for example people end up having to commute to the Coventry Gateway project then and is contrary to a sustainable community and contrary to the declared aims of the Gateway project.
Infastructure
The current infrastructure is completely unable to meet the demands that would be placed upon it by new construction in the greenbelt to the North of Leamington Spa. This means that new land would be needed for a Northern Relief Road. Land that is so unsuitable for development that it requires a £28 million investment to make it suitable - again hardly justification for exceptional circumstances to build on the greenbelt. Professional opinion further suggests that this £28 million is an understatement and costs would be far higher. Furthermore this relief road would destroy the character of Old Milverton, one of Warwickshire's greatest villages. I believe this should not happen, particularly because Old Milverton is a conservation zone an "areas of special architectural or historic interest, the character or appearance of which it is desirable to preserve or enhance." It is therefore unsustainable to destroy such a village's character, and furthermore irresponsible after the residents have spent so many decades preserving their village for the council to destroy it themselves on the basis of inappropriate planning decisions. Additionally this development is a waste of council money, for although the cost of the relief road would be met by the developers if an alternative site was chosen this funding could be spent on other requirements for a new development required by the council, eg schools/cycleways. The problems with infrastructure costs also link back into arguments regarding the cost of housing to consumers; the housing developers are commercial companies and they will pass on the cost of building the relief road to those who go on to purchase the houses. The council has already recognised the importance of building affordable housing and therefore questioning construction in the already expensive North Leamington, but adding to the cost of housing due to the need for a relief road will only make the housing more expensive and inaccessible to the people, who like myself who cannot afford housing.
The recent disastrous modification of infrastructure in Jury Street Warwick demonstrate the poor ability of this country to develop it's infrastructure appropriately, and the public have no faith in the council's ability to successfully deliver such projects, therefore the insertion of a £28 million relief road is of great concern to residents, there is shockingly little evidence in the local plan as to how this would be successfully implemented and local residents can only fear it would be as disastrous as other plans without this evidence base; it is put in we believe as an afterthought to justify construction on the greenbelt land, and must therefore, along with it's concurrent development, be removed from the development plan.
The plan argues that turning the A452 between Leamington and Kenilworth into dual carriageway would be a benefit to the area, however a more thorough assessment by the council would identify that at peak times delays on the A452 result from commuters wishing to access the Town Centres, which a dual carriageway would do very little to improve.
The Northern relief road planned by the council will form an artificial barrier, which will encourage further unacceptable development that will further destroy old Milverton; risking such a development is inconsistent with the NPPF and Regional Spatial Strategy, as Milverton should be protected under policy RR1 of the RSS.
Housing Provision
I personally believe that there is an over-provision of housing in the preferred options plan, this occurs because the Council is relying on projections from a past period of exceptional growth, that is very unlikely to be continued. Furthermore even if the proposed housing demand was accepted then amazingly the preferred options plan could have the housing removed from the greenbelt sites without causing a deficit and this is without other (more suitable) alternative sites, as suggested below being substituted. Quite clearly therefore exceptional circumstances cannot be justified for construction on the greenbelt, and this wouldn't be accepted at later stages of the process if/when such a development was inspected/contested. For this reason I strongly believe that the result of the consultation should be the removal of construction from the greenbelt land, due to overprovision of housing alone (but with the potential for including other sites if the results of the consultation seem necessary). I feel particularly strongly that this argument should be accepted and included in the future plan for it was the leader of the council stated at the Milverton Parish Council meeting that if we thought there was overprovision of housing then we should say so. This must therefore be a valid reason to object and one I expect to be taken onboard.
SECTION 2: Need to consistently align Local Plan with West Midlands Regional Spatial Strategy
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.
SECTION 3: More Appropriate Sites
Previously identified viable sites
The quite remarkable problem with the Council's plan is that a previous plan (Core strategy plan 2010) identified ample land within the district without resorting to construction on the greenbelt, this fact alone means that there must be adequate land elsewhere to build on, thus there cannot be exceptional circumstances to justify construction on the greenbelt land, when nothing significant (except the publication of the National Planning Policy Framework stating that greenbelt land should not be built on unless exceptional circumstances) has changed in the district. Indeed during this consultation the council has suggested that people objecting to the greenbelt land use must not just state they don't wish that land to be developed, but suggest alternatives; I propose to you that at least one valid alternative has already been part validated is the Core Strategy Plan and this can be used as a solution to ALL THOSE PEOPLE who are objecting to the greenbelt. At the Milverton Parish meeting the a senior officer of the council suggested changes had been made to the Core Strategy Plan's of building in the South due to infrastructure problems, however this is hardly sufficient to justify building in the North; a significant infrastructure investment in the South (akin to the Milverton relief road proposed for the North) could sort out the infrastructure problems there, and whilst significant investigation has gone into the South's infrastructure and congestion problems woefully little has gone into examining the North. In short selective investigations have been completed to rule out land the council has decided not to build on, whilst no such investigation has gone into land they do wish to build on. A carefully examination of current and future congestion in the North should have been completed before the plan was decided on (not after), it is now impossible to complete a post-hoc analysis without bias creeping in to favour development in the North. It is very clear from the congestion currently in the North that already exists that further development would only exacerbate this, whilst the South is already better placed with easy access to the M40.
Warwick District Council have argued that land in South Leamington is not as attractive to developers because concentration of development in that area may result in developers making less profit - financial gain quite clearly cannot be expressed as a "very special circumstance" to permit unnecessary development in the Geenbelt land.
Radford Semele
There is ample room to move a significant number of the greenbelt housing allocation into and around Radford Semele. This preferred options allows for 500 houses in Category 1 villages, this a low proportion relative the total requirement and across the Category 1 villages which are not in greenbelt land there should be a significantly more houses planned for there. The preferred options document does not identify those specific sites surrounding villages that are suitable to meet the 500 houses target, not only should this be done but it is very likely these villages could absorb more accommodation, potentially even a doubling and this would be preferable to current plans to build on the greenbelt.
Whilst at Radford Semele there is a possible argument against coalescence significant sites still remain; R67 and R41 total 11.16 acres, and seem to have been excluded due to the presence of gas mains, these gas mains require a 100m exclusion zone, however both sites could in fact be extended towards the gas main and remain outside the exclusion zone. Indeed the garden town approach to development would easily allow these exclusion zones to be incorporated into the required green space and cycle-ways that the council is so keen to provide. Professional advice suggests there is significantly more housing that could be built in this area near the gas mains and still conform to planning law, it is essential the council reconsider this and identify how to extend the provision in this non-greenbelt land. Furthermore the site boundary of R41 does not seem to follow and fence or hedge line and could therefore be extended significantly, even if there is a fence/hedge line the site could still be extended to include more land to boundaries further out, or boundaries could be completed. Flooding risk to the Warwickshire Exhibition Centre is stated as a risk, but this is over a km away and is of negligible import - this needs to be reconsidered and potentially simple flood alleviation methods installed. Furthermore site R56 to the West of Radford Semele was also identified as being suitable subject to alleviation of flooding issues and is an excellent site given that it would not contribute to coalescence, again the garden town approach to the development would allow the incorporation of flood alleviation schemes, and thus these schemes and this site (potentially also enlarged) would be far preferable to construction on the greenbelt. Any risk of coalescence between Radford Semele and Leamington is dwarfed in comparison to the consequences of risking coalescence between Leamington and Kenilworth/Coventry as produced by building on the Northern Greenbelt and it is far preferable to build here; indeed almost all towns across the UK have grown by inclusion of local villages and there is little reason why the open space between Radford Semele and Bishop's Tachbrook should not be used such given this is not greenbelt land.
Grove Farm
Grove farm also could provide additional housing, removing the need to build on the greenbelt; L09 we are told by David Barber (via Councillor Bill Gifford) has not been developed for the main reason of coalescence, but even if this site was developed there would still be 1km between built up areas, this would provide a suitable green wedge, though personally I believe building on this wedge would be preferable to building on greenbelt land. Indeed significant areas of land have been discounted as they would result in coalescence or the destruction of a greenwedge; however discounting these sites whilst building on greenbelt land is contradictory to the national government policy outlined in "Strategic gap and green wedge policies in structure plans: main report." The document states "There would be significant problems in giving strategic spaces and green wedges the status of greenbelts. Strategic gaps as greenbelts would reduce peripheral land development options on the edge of large settlements, often in sustainable locations. Problem over the interpretation of prominence and the possible need for safeguarding land would also occur. If green wedges were given Green Belt status then the area covered by a strong presumption against development would be more closely drawn into cities and large towns". This demonstrates that the status of greenbelt is above that greenwedges, so the wedges should be built on fir
Other Sites
Site L09 should be reassessed as it is more suitable than the greenbelt suggested to be built on, the problems outlined in the SHLAA are less than the problems with building on the North Leamington greenbelt. Site L09 is not in greenbelt land, objections that the land would need employment and infrastructure are no different to the problems identified with the greenbelt land the council intends to build on, and the development of the countryside is not an serious reason not to build on the land when in contrast you want to build on the greenbelt. The topography would not provent sensibly designed/developed housing.
It is quite simply idiotic that site W07 is not being built on, currently the council propose building on greenbelt land rather than improving the county by building on slurry contaminated land, which is in my opinion effectively brownfield land. Indeed the council even identify it as suitable for development once ground remediation work is completed.
W03 is exactly the same - it slurry contaminated land, identified as suitable for development after ground remediation works should be built on prior to brownfield sites. The arguements in the SHLAA regarding whether the market could support it is bizarre - if the market cannot support such land then certainly land to the North Greenbelt requiring a £28 million+ relief road isn't needed because there wouldn't be demand!
Furthermore considerable research and indeed I believe actual inclusion in the plan should go into the development of a new village(s) to the South of the district in the extensive non-greenbelt land there, such virgin land would be hugely attractive to developers, and there is ample space to build such a site without contacting existing rural settlements and therefore avoiding harming their character. Indeed I issue it as a challenge to the council and the planners to include such a site, using imagination to create a garden village, which would be a true innovation in our district and one of which all local residents could be proud.
Whilst it is clear that a plan such as the Preferred Options plan produced by the council cannot be expected to please every resident in every area of the town, it is the council's responsibility to listen to arguments that are based on clear planning policy and supported in numbers. The arguments produced against development of the North Leamington greenbelt are backed by a substantial number of residents and backed by firm planning policy either National (eg the National Planning Policy Framework), Regional (The Regional Spatial Strategy for the West Midlands), or Local (ensuring development is in accords with WDC's aims as stated in the consultation document). Opposition in the South from my experience is centred around a lack of infrastructure, schools, and an over-burdening of development there. None of these are firm planning reasons; the council have very clearly identified that local infrastructure can be put in place by developers and the M40 provides an excellent foundation for this countering that argument, wherever there is new development there will be new schools and the council must do more to persuade residents that this will be the case, and finally the concerns of overdevelopment are a "NIMBY (not in my back yard) argument backed up by no sound planning arguments - indeed there are plans to build a New Mildland City in the Meridian Gap is supported by national planners and shows that this region has the need and ability to support a substantial amount of housing in one area, and whilst nothing of this size is proposed for Warwickshire it quite clearly demonstrates that whatever the council proposes it would not be an overburden in an area that in now way risks coalescence with another town.
SECTION 4: National context
It is vital that all those involved in the consultation process do not become blinkered in their view, but respect the national context within which this plan stands. The importance of the "National Planning Policy Framework's" AND "Strategic gap and green wedge policies in structure plans: main report protection of the greenbelt land" have already been highlighted, as well as the failure of the current plan to take account of these - which I imagine will be a major problem when the plan is submitted to the inspectorate. There is however even more evidence of the importance of greenbelt land, which should be considered with regards to this plan.
The government's original proposals for planning policy (the draft national planning policy framework) provided very little protection to the greenbelt land, however it was immense public opposition to this with nearly a quarter of a million people signing a petition organised by the national trust (a scale unprecedented for a planning policy document) that resulted in greenbelt land being protected as per the final document, and as ignored by the preferred options plan. This clearly shows however the immense value the nation place in greenbelt land, and in the protection provided for it by the National Planning Policy Framework. The preferred options plan fails to take account of this and residents in the North, myself included feel it is of national importance to ensure the NPPF's protection are not ignored, particularly by an executive committee of the same political party as the government who instituted the plan, and we believe we would have national support if our arguments were to be wrongly ignored during the consultation. It is afterall the people of the nation that we wish to attract to Warwick District to live, work and play!
SECTION 5: The consultation process
Omissions from Consultation
Whilst trying to understand the Council's reasoning for what seems to be a highly unusual plan it has come to my attention that there are two key omissions from the consultation that are either being used as justification for the plans submitted, or used to contradict local residents views and arguments, this does not make for a fair consultation and produces the view held by many that the council are determined to build on greenbelt land to the North, and then find any planning evidence/arguments that justify their desires. This is not a sound grounds for consultation and it can only be made fair if such arguments are ignored. My chief concerns are listed below.
Senior individuals within the council have stated that previous opposition to development in South Leamington, particularly around Bishop's Itchington have prompted the need to force development on the greenbelt in this plan. If this were to be a valid basis for planning then it is of vital importance that such information is included in the consultation document - yet it is not. The absence of discussion on this matter within the consultation document, as well as the fact that this would result in a plan based on a popularity contest/political pandering rather than sound planning principles means that additional development in the South should not be excluded with resultant development on the Northern greenbelt. There has been tremendous resident opposition in the North (see submitted petitions of over 2000 individuals) alongside strong planning arguments dictated by National Planning Policy, which the council are compelled to follow, and on which basis the plan will be judged when sent to the inspectorate. It may not be possible to please all residents with the subsequent plan to develop the town, but the council's responsibility is to listen to the views of this consultation and build their plans based on the views of local residents that are supported by sound planning arguments.
Another senior member of the council has stated that the need to develop on the Northern Greenbelt stems from a need to provide worker accommodation for subsequent employment land at the Coventry airport site. However it is not identified in the consultation that such land has been allocated for this purpose and it would be impossible to allocate such land at the stage for which the consultation document was written (and the greenbelt land assigned to development land) as the document states with regards to the Coventry gateway site that "It has the potential to provide in the region of 14,000 jobs as well as facilitate major improvements to the transport network. The Council is supportive in principle but considers that further work is needed to justify the identification of this site." The (very senior) officers justification of such a site for Coventry housing is therefore an afterthought, not explained in the consultation document with no evidence base to suit such a project and a major omission from the consultation document. Furthermore such a claim that the land is to be used for commuter land with respect for Coventry is inconsistent as land closer to Coventry has been identified as suitable for development, yet not included as suitable land for the construction of housing. Additionally there is a huge expanse of greenbelt land between the proposed North Leamington greenbelt site and Coventry which would be closer, with reduced environmental/congestion impact that would be suitable for that housing. It is totally impossible to justify exceptional circumstances to build on the greenbelt to the North of Leamington for such a development in Coventry without a detailed analysis of the situation, which should be provided with evidence.
A further key omission from the document is that despite Warwick District council performing a study of greenbelt land between Old Milverton and Blackdown, which concluded that these areas had high greenbelt value, this information was consequently rejected from the consultation document, or if it exists and I cannot find it - then it certainly has not been used to sufficient extent.
Expectation that resident views/submissions to consultation will be ignored
I am deeply concerned about the nature of this consultation process, and I like very many other residents feel that our views will be ignored despite strong objections by letters submitted to yourselves, petitions, and exceptional attendance at public meetings such as the North Leamington Community Forum and Milverton Parish Council. Indeed we have been told one member of the council explicitly stated that residents should get used to the plan as it would go through regardless - quite clearly bringing into question the fairness of the consultation. National government policy states the importance of localism to ensure that the views of local people not ignored and I believe the council must take the views of North Leamington residents on board, and act on them.
The consultation process has asked for the views of local residents, which I believe have been strongly voiced in terms of not building on the greenbelt land to the North of the town. I believe it is the councils responsibility to listen to these views as part of the consultation, take them on board and change their plans accordingly. It is not the councils responsibility to argue with these views, cite counter evidence, or employ professionals to create reasons/argument to ignore such views. Indeed the council's documentation for the consultation has not provided all evidence that was used to create their plans, therefore limiting residents to only being able to provide their views and not assess and counter all the evidence. All residents could therefore do is provide their views, which must then, in my opinion by listened to and acted on, as there is nothing else they could provide. Furthermore the document is referred to as the "preferred options plan" however there are NO options as to which land could be built on, therefore as local residents have objected to construction to land on the greenbelt the council must then seek alternative land and submit this to the second consultation round with the greenbelt land removed. The council must not ignore over 2000 residents views resisting construction on the greenbelt because the residents (who are not planners) have not all identified land elsewhere, there is as demonstrated here alternative land, and it is the councils responsibility to search an alternative option.
The strength of opposition I have seen from local residents to not building on the North Leamington greenbelt demonstrates that if the council fails to take on board views of the residents as a result of this consultation then I firmly believe those views will only be expressed more strongly in the second period of consultation and stronger still following that if our views continue to be ignored. I and others would have no hesitation in involving national groups and media attention in opposing these plans, which I and others so strongly object to. It is irresponsible of the council to risk a failed plan. The council have repeatedly told us that if a plan is not submitted and accepted then developers will be free to build wherever they want and there will be a lottery of developments (this sounds remarkably like a threat to residents not to submit their views and oppose the plans), however in fact it is the councils responsibility to ensure that we are not left in this situation by taking on board, and acting on the locals views. It will be their fault, not ours if we are left without a plan. Furthermore it would be foolhardy of the council to risk the phenomenal cost in fighting local residents legally, on which I believe the council would have little no grounds to proceed, there are many far better things to spend money on. From the strength of opposition I have witnessed I have little doubt that if the council ignored North resident views then there is the demand and resources to pursue this fight further.
At a recent Milverton Parish Council meeting the chairman of the council announced to the approximately 150 people there who opposed the plans that they should not write to their local MPs. The people at the meeting had widely expressed their view that the council had failed to put in place National Policies developed by their MPs' government. I, and everyone else there saw it as entirely appropriate to write to our MPs, but again the Council seemed determined to allow nothing to influence their views and seemingly politically motivated plans for the county. This is furthered by the title of the consultation document - "Local Plan Preferred Options" for a plan that does not contain a single option as to the provision of housing land.
Online Submission Form and Information Provision
The online submission form that Warwick District Council has as the main way to register submissions to the consultation is not fit for purpose. Firstly the system is incredibly complex, with the need to register to even access the system, and once there a bizarre system that took me a considerable amount of time for me to fathom, once completed you must object on particularly items/sites - this is despite the repeated messages from the council that they do not wish people just to object but to provide solutions and say where they would like to build. The system is not fit for this purpose. In fact I have not before seen such a poorly designed online data collection tool. Furthermore a considerable number (of intelligent computer literate) people have failed to access they system and to understand how it operates. These points suggest to me that the council is less than interested in the views of the local population, for it would not have been difficult to design a far simpler, user friendly system, accessible to the young/old alike.
Leamington library has been advertised as a location of consultation information; however this could only be viewed once asking at the desk, from whence a box containing the information was produced. If the council genuinely respected the views of local residents an eye-catching display could be simply and cost-effectively be erected to attract attention. Similarly when visiting Warwickshire College to view the information, reception at the College did not in fact know that the information provision existed, it was only after ringing the council that the information became apparent.
These points are not intended to be taken as a "moan" but rather when taken together they demonstrate that it is not surprising that residents of North Leamington feel that their views will be ignored, and it is essential that the petitions and letters such as the one above are taken onboard and acted upon by the council to ensure the North Leamington Greenbelt is protected.
Concluding Remarks
The plans as they stand are totally unacceptable in that they involve greenbelt on the land to the North of Leamington Spa. In particular the land to the North of Northumberland Road and South of Old Milverton is one of the most used pieces of greenbelt in the whole district, with immense amenity and health benefits. The planned construction in the greenbelt is contrary to the national policies of the "NPPF" and "Strategic gap and green wedge policies in structure plans: main report." The immense local opposition to this plan and the National Policy of Localism mean the greenbelt sites to the North of the town should be excluded permanently from the plan.
The council has a choice; they can devastate the character and attractiveness of a unique Royal Spa town, that has been cherished and lovingly developed for centuries OR the council can seek an alternative option. The alternative option will need their imagination and determination to build on the views of the populous, but it will build a town of which we can be rightfully proud for decades to come.