1 INTRODUCTION
1.1 RPS Planning and Development (RPS) has been instructed by Lenco Investments (Lenco) to
prepare representations to the Warwick District Council New Local Plan Preferred Options
consultation document, in respect of their land interests at Baginton.
1.2 Warwick District Council (the Council) has proposed their Preferred Options in terms of housing
and economic growth and their vision for the district generally over the plan period to 2029.
These are currently being consulted upon until 27 July 2012.
1.3 RPS has made representations on behalf of Lenco to the previous stages of both the Warwick
Local Development Framework and the Coventry Core Strategy, to ensure a suitable approach is
taken to cross boundary development led growth.
1.4 Lenco's land interests at Baginton relate to a site which lies to the south of Baginton village
situated within the Green Belt, as shown at Appendix 1. It is important to note that Lenco has the
controlling interest in the majority of this land.
1.5 The site Lenco has interests in lies to the south of Baginton village, and. The site extends to
approximately 50ha and is in a sustainable location within easy access to Coventry City Centre,
close to the perimeter edge of the airport, with excellent cycle, pedestrian access to the
surrounding areas, and vehicular access to major transport links such as the A45 and A46.
1.6 Whilst the site falls within the local authority area of Warwick District it remains very close to
Coventry's administrative boundary, as well as the major sub regional employment base centred
on Coventry Airport. RPS is aware of the current proposals to expand Coventry Airport, and a housing development at Baginton would support these expansion plans.
1.7 The representations, therefore, address the need for housing growth within Warwick
administrative boundary and suggest that large-scale growth should be situated within close
proximity of employment development to ensure that people can live and work in close proximity.
Such proposals will support the Government's objectives to encourage economic growth in order
to revive the economy. Furthermore, these representations address the need for cross-boundary
growth and for full and proper cross-boundary working to be established between, Warwick,
Coventry and Nuneaton and Bedworth Boroughs as required by the Localism Act and NPPF.
1.8 The following chapter provides details about the site at Baginton, and our comments in response
to the Preferred Options document are provided in Chapter 3 and are set out in the same format
as the Council's response forms.
1.9 RPS are willing to meet with Planning Officers from Warwick District Council again concerning
Lenco's land interests and the New Local Plan process to discuss the potential of the site in
meeting local housing needs.
2 LAND SOUTH OF BAGINTON
2.1 The site Lenco has interests in extends to approximately 50ha and lies to the south of Bagington
village. The site is in a sustainable location close to Coventry City's boundary and the urban
area, and within easy access to the City Centre, and major transport links such as the A45 and
A46. The site, being close to the perimeter edge of the airport, with excellent cycle, pedestrian
and vehicular access, provides an exceptional opportunity for the provision of balanced housing
growth in the most sustainable manner.
Planning Policy
2.2 The Local Plan Preferred Options promotes 10,800 new dwellings within Warwick District for the
plan period up to 2029, at an annual delivery rate of 600 dwellings a year.
2.3 Evidence advanced by the West Midlands regional assembly for the West Midlands RSS
Examination in July 2009 from the Cambridge Centre for Housing and Planning Research,
based on 2006 ONS Household Projections and allowing for the economic downturn, concluded
that Warwick District's housing requirement between 2006 and 2026 was 18,200 dwellings at a
rate of 910 dwellings/year. Whilst the RSS is not longer in place, the evidence base is still to be
taken into account by Local Planning Authorities in preparing development plan documents.
2.4 The 2012 Strategic Housing Market Assessment indicates a requirement of 698 dwellings a year
to meet the affordable housing needs of the District in addition to market housing needs, which
is significantly higher than the level of housing currently being proposed by the Council.
2.5 The 2008 ONS Household Projections predicted an increase of 17,000 households between
2008 and 2028, at a rate of 850 dwellings a year. This represents an additional 150 dwellings a
year than is currently proposed through the Local Plan, which clearly will not meet the District's
identified need for new homes.
2.6 RPS is also aware that the 2012 SHLAA indicates that the District has a supply of deliverable
sites to provide 13,385 dwellings between 2014 and 2029, excluding windfalls, which is greater
than the numbers proposed within the Local Plan. Therefore the Council has identified the
ability to deliver housing sites at a higher annual rate than is currently proposed through the
Preferred Option.
2.7 RPS, on behalf of Lenco, therefore believes that the proposed figure of 10,800 new dwellings is
insufficient and that a higher level of growth would better reflect the projected population
increase and ensure that identified housing needs can be met, as suggested within the evidence
base. The Council cannot meet a higher target without locating housing on greenfield of Green
Belt land, and therefore should consider sustainable locations outside of the urban areas to
ensure housing needs can be appropriately met.
Cross-boundary Growth
2.8 The NPPF states that Local Planning Authorities have a 'duty to co-operate' on cross-boundary
planning issues, in particular for strategic priorities including housing, to meet development
needs which cannot be met solely within their own administrative boundaries.
6 rpsgroup.com
2.9 It has been recognised in Coventry's SHLAA assessment that the Council cannot meet their
housing targets on land within their administrative boundary alone. It is considered, therefore,
that Green Belt locations on the periphery of the urban area should be recognised as
appropriate locations for accommodating future growth.
2.10 The Green Belt south of Coventry was recognised through the Warwick Core Strategy process as
being an appropriate location for accommodating future growth of the City. Although the site is
within Warwick District it lies close to Coventry's administrative boundary, as well as the major
sub regional employment base centred on Coventry Airport.
Coventry Airport
2.11 Whilst both Coventry Airport's major sub regional employment base and Baginton village are
located outside of Coventry's local authority boundary, they are socially and economically
associated and physically adjoin the Coventry urban area. Residential development in this
location at Baginton could balance the existing significant employment base on the southern
side of Coventry, such as those around the airport at Stonebridge Trading Estate and
Middlemarch Business Park, both of which are within a very short distance of the site, as well as
the air freight and terminal employment opportunities.
2.12 RPS is also aware of the current Coventry and Warwickshire Gateway Scheme proposals
(Appendix 2) to expand Coventry Airport, and a housing development at Baginton would support
these expansion plans. RPS recommends that housing supply is focused in those areas where
there are important benefits to be gained where future economic growth is planned.
Site at Baginton
2.13 A residential-led mixed use development at Baginton could contribute sustainably to crossboundary
growth as required by the NPPF, and to meeting both Warwick District and Coventry
City's housing needs by delivering approximately 1,000 new homes either in isolation or as part
of the wider regeneration proposals for the area. The location of the site in relation to the
Gateway proposals is shown at Appendix 3.
2.14 Development at this location would also allow for new facilities and services to be provided,
making the best use of existing and proposed infrastructure. The site can be appropriately
phased over the Local Plan period to develop an available, suitable and deliverable urban
extension proposal.
2.15 The promotional document 'Land south of Baginton: A Sustainable Urban Extension' prepared in
2008 has previously been submitted to the Council and provides further details of how the site
could be sustainably developed.
2.16 In addition to this, extensive technical surveys in relation to flood risk, noise, ecology,
conservation and heritage, landscape, and highways have been undertaken of the site and
submitted to the Council, to demonstrate the site's suitability for a significant residential-led
development either in isolation or in connection with proposals for the wider area. An Air Quality
Assessment will also be undertaken to demonstrate the site's suitability for development.
2.17 RPS, therefore, considers that to help deliver greater sustainable development opportunities, it is
important that sufficient housing land comes forward in areas of proven market demand, such as on this Green Belt site to the south of Baginton, to contribute towards delivery of additional
dwellings and higher levels of growth to meet the needs of both Councils.
2.18 Responses to individual policies and topics within the Preferred Options consultation document
are included in the following chapter

attached letter

Dear Sirs,
Please find below my views regarding the Consultation for the New Local Plan. I am
submitting this as a letter because the consultation web site appears unreliable and also
does not appear to allow me (as requested by the Council) to make alternative proposals. It
only appears to allow me to make comments on particular sites.
SUMMARY
I am totally opposed to the plans to allow development on the Green Belt to the North of
Leamington Spa and the complete change in direction since the 2009 Core Strategy
document. There is no evidence or requirement to change any of these North Leamington
Green Belt Boundaries.
In particular I oppose the proposed developments to the Milverton Gardens (North of
Milvertion) and Blackdown. Your references are I believe are L03 and L07 together with L48.
L07, and L03 in particular, must be among the highest public amenity value of any rural
space in Warwickshire providing very highly used public footpaths from two access points
directly onto open country side.
The Green Belt has been vital in maintaining the identity of the Warwickshire towns for
many years and Government policy under NPPF is very clear regarding the importance of
preserving Green Belt.
The Council have not demonstrated the required very special circumstances to build on the
Green Belt to the North of Leamington. It is therefore unacceptable to change the Green
Belt boundaries to the North of Leamington.
Plans for a major new relief road, to alleviate the traffic caused as a consequence of the
proposed new housing, only causes further loss of Green Belt and is unjustified.
Housing should be provided, as the previous 2009 Core Strategy document, to the South of
Leamington Spa where the employment and infrastructure exists and where there are not
the issues of coalescence.
The evidence base is not sufficient for the preferred plan to be derived from it. It fails to
provide balanced investigations of the considered sites. It is clear that it must have been
used to attempt to justify a politically motivated plan to 'share the pain'. Further evidence
of this has been provided from Council responses to enquiries with statements that the plan
has in fact arisen as a result of lobbying pressure from South Leamington.
Other such statements have indicated that the reasoning behind the proposed housing to
the North of Leamington Spa also relate to assumptions about employment arising from
around Coventry airport. This would be inappropriate because housing should be provided
close to the employment in Coventry providing a more sustainable future with shorter
commuting. Furthermore the Council should be planning to invest for employment in
Leamington Spa rather than making Leamington a commuter area for Coventry. If this was
part of the reasoning for the plans, then this should have been made clear in the
consultation documents for people to comment upon. If on the other hand employment
arising from Coventry airport was not part of the reasoning behind the proposed housing to
the North of Leamington Spa, then the Council should not be using it as a justification in
responding to consultation questions.
On a positive note the proposals to enhance the quality of the proposed new housing
developments (along the lines of garden towns) is positive and would be an asset to, and
raise the housing diversity in, South Leamington Spa.
EVIDENCE BASE
The Council Preferred Options plan are not, as we would be lead to believe in the Forums,
developed from an evidence base. On inspection there are significant omissions in the
evidence base and significant conclusions are included in the plans which are not supported
by the evidence base. The only conclusion I can make is that the evidence base was
developed in retrospect to try and support a political plan to 'share the pain' or 'spread it
about'.
Not only does the evidence demonstrate this lack of consistency in approach, the anecdotal
comments from some Councillors, as well as presentations by officers, have demonstrated
the back to front approach to developing the plans.
When pressed for an explanation regarding the errors in the statistical analysis of the
population growth, Councilors have made the statement that the council settled on the
required number of houses "as what was considered we could get away with".
There is over-provision of housing resulting from the Council making projections from past
population data which includes a period of exceptional growth. Calculations of future
population should have more accurately taken account of the reducing trend in population
growth, rather than having an unlikely high projected population as a result the past, short
period, of abnormal high growth. If the calculations and projections exclude the period of
abnormal growth then the housing on the Green Belt is not needed.
The Council has stated in forums that the infrastructure to the South of Leamington Spa has
been investigated and found not to support the required number of houses. However they
also state that their infrastructure plans to the North are not yet completed. Request for
details of the traffic surveys established that they have not in fact been carried out. This is
further evidence that the infrastructure investigation is being used to justify the plan rather
than being the basis for it.
The Council have concluded that more houses in the South of Leamington Spa than is
allocated in the plan cannot be delivered. This is not evidenced anywhere. When challenged
in Forums, the Council stated that the Developers with whom local residents have consulted
(to confirm that the Council assumptions are incorrect) cannot be trusted 'because they
have a vested interest'. Can it be that the Council have therefore only consulted with
Developers / Landowners of the Green belt to the North? Clearly these parties would have a
far greater vested interest to have the Green Belt boundary redrawn!
What appears more likely is that the Council have simply made an assumption on
deliverability rather than carry out a proper investigation. It would appear that the Council
have lost track of the phased nature of the delivery requirements when considering the
deliverability argument.
The conclusion that the area to the South of Leamington Spa cannot accommodate more
homes and therefore there is no option but to put the houses on Green Belt is not
evidenced and is incorrect.
GREEN BELT
The reasoning behind relocating the development from South to North of Leamington is the
result of previous objections from South Leamington with no account taken of the
underlying planning advantages which exist. It is a purely political move.
The Local Plan is governed by the National Planning Policy Framework (NPPF) which clearly
states that Local Plans must accord with its principles. The value of Greenbelt is set out in
the NPPF to prevent urban sprawl by keeping land permanently open. Green belt land
should not be developed when other suitable land is available for development.
The National Planning Policy Framework (NPPF) 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. The Greenbelt land identified for development in the Preferred
Option does fulfill the majority of these purposes and its development would therefore be
contrary to the NPPF.
The NPPF requires there to be "very special circumstances" for development in the Green
Belt. It also requires the harm caused to the Green Belt by the development to be
outweighed by the benefit of the development. According to Warwick District Council the
very special circumstances are that there is nowhere else for the homes to be built. This is
demonstrably untrue.
The Council identified available land east of the A452 (Europa Way) and south of Heathcote
towards Bishops Tachbrook however these sites have not been included in the Preferred
Options sites. Presumably, this is because of the policy of 'spreading it around'. That is not a
planning policy, it's a political policy.
The proposals ignore Warwick District Council's study of the Green Belt land at Old
Milverton and Blackdown, which concluded that these areas have high Green Belt value.
The proposals will reduce the "Green Lung" between Leamington and Kenilworth to less
than 1 1/2 miles.
Planning policy dictates that Green Belt must be valued more highly than Green Wedges.
Therefore the Preferred options are flawed as the opposite has in fact been planned.
NO EVIDENCE OF ANY VERY SPECIAL CIRCUMSTANCES FOR DEVELOPMENT ON
GREEN BELT
No "very special circumstances" have been proven for the use of Green Belt land.
The Council's own previous plan the "2009 Core Strategy" accommodated significantly more
houses and identified suitable sites without using Green Belt. The land south of Leamington
Spa (not in Green Belt), was identified and is still available, for development.
The assessment performed by Warwick District Council shows that this land to the south of
Leamington is easier to develop and already has a substantial amount of infrastructure to
support the development, and the new residents who will live there. It is close to the M40
and there are existing employment opportunities in the South of Leamington Spa as well as
existing out of town shopping facilities and good access to the town centres.
Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are
alternative areas for development other than the Green Belt and that consequently there is
no evidence that very special circumstances exist to change the Green Belt Boundary.
Warwick District Council argues that the land in the South of Leamington is not as attractive
to developers because 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. Concentration
of development would encourage the housing to be competitively priced and more
affordable when built in the south of Leamington Spa.
RECREATION VALUE OF OLD MILVERTON AND BLACKDOWN
Milverton Gardens (North of Milvertion) is an important local amenity for exercise and
recreation as there is very little alternative publicly accessible open space in this area.
It is enjoyed by many walkers, runners, riders, and cyclists. It provides a countryside
environment close to the neighboring areas of Leamington Spa. Evidence has also shown
that people are traveling from the Centre and also the South of town to use the amenity,
further demonstrating the value of this amenity to a wide community.
Both the proposed building development and the "Northern Relief Road" would
substantially reduce the amount of land that is available to be enjoyed and have a
catastrophic detrimental impact on the ambience and hence the amenity value of the land.
The implication that somehow the proposed type of development will magically turn some
of it into a maintained park land is both unlikely and unsustainable. It would also detract
from, rather than enhance its value; managed parkland is a poor substitute for access to fine
agricultural land.
North Leamington Forum recently (and ironically at the presentation of these plans!) had to
allocate funds to struggling local groups trying to maintain and create small recreation
spaces within housing developments which the Council will not / or cannot afford to
maintain. This demonstrates the value of the currently free amenity which the community
enjoys.
North Leamington Spa does not have parks such at Victoria Park and Jepson Gardens as do
other areas of Leamington Spa. This area of Green Belt provides an invaluable and
irreplaceable open and free resource to the community. A great many signatures have been
collected on petitions in support of keeping this amenity.
The Housing Assessment fails to identify the footpath between Milverton and Old
Milverton. Policy QE4 in Regional Spatial Strategy for West Midlands states that footpaths
and the green spaces around them must be preserved. The document is being used
powerfully at the moment in the "evidence base" to support council desires, yet has been
heavily cherry picked. Indeed Policy QE6 states "Local authorities should
conserve...protecting and where possible enhance natural features that contribute to the
character of the landscape and local distinctiveness"
INFRASTRUCTURE / PROPOSED NEW ROADS
The Northern Leamington Relief Road, at an estimated cost of £28 million, would ruin Old
Milverton and divert resources from other much needed public investment. As a Charted
Quantity Surveyor it is evident that this estimate is unlikely to be the maximum outturn cost
considering the ground over which the road must run and the bridges and retaining
structures which will be necessary together with the other costs which will be attributed to
it.
Traffic flows in the area tend to be north to south rather than east to 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 Town. If the development does not go ahead the
road will not be required.
Turning the A452 between Leamington and Kenilworth into 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. Building nearly 3000 houses north of Leamington will simply increase the
congestion. The dual carriage way will have a detrimental effect on the picturesque
northern gateway to Leamington and southern gateway to Kenilworth.
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 and will
violate an important nature corridor along the River Avon.
If the proposed development is concentrated in the South of Leamington there is an existing
road network that could be upgraded at considerably lower cost than the £28m allocated to
construct a "Northern Relief Road" so reducing the sale price of the houses.
NEW OUT OF TOWN STORES AND EMPLOYMENT
The proposed "out of town" retail operations will be another blow to independent retailers
in Leamington, Kenilworth and Warwick who make the area an attractive place to live.
Further "out of town" shopping will take trade away from the Towns.
However the Council have stated at Forums that they don't plan out of town shopping,
apparently therefore the Consultation information is inaccurate?
They have also played down the concept of new employment land in the Green Belt in these
same Forums and have been totally unable to give details at to what is alluded to in the
Consultation by these phrases. They indicate this has yet to be thought through. Further
demonstrating that the evidence base is still being developed to justify the plan not the
other way around as should have been the case.
LOSS OF AGRICULTURAL LAND
There will be a loss of a significant amount of high quality agricultural land in Blackdown and
Old Milverton which is unnecessary.
OVERALL LEVEL OF HOUSING PROVISION / NUMBER OF HOMES INCLUDED IN THE
FORECASTS
There appears to be over-provision of housing resulting from the Council relying on
projections from a past period of exceptional growth as noted earlier.
Furthermore the Council have agreed in the Forums that there is a "contingency for the
consultation" to the tune of at least 1400 homes. Detail investigation of the low numbers
assumed for allocations on sites such as the Fire station and other town centre sites indicate
that there is also a further 'hidden' contingency.
The Council appears to be building contingency on contingency. Consequently, even
accepting the population and demand projections, the units proposed for the green belt to
Milverton Gardens (North of Milvertion) can easily be deleted without causing a deficit,
even if no alternative sites were substituted.
The situation is exacerbated in that having identified non Green Belt Land as suitable for
development, but then having rejected it without adequate justification, there is a real
possibility that the owners of this will gain planning permission on appeal resulting in
further over provision of land.
Returning to the 1400 homes contingency alone. If this "buffer" is removed from the
forecast there is no need to include the Green Belt land at Milverton Gardens (North of
Milvertion) (L03 & L07) in the proposals.
ALTERNATIVE PLAN
The Council have said in Forums that in making objections to the plan, residents should also
give solutions. However the Council have done little to publicise the very short 8 week
consultation. Furthermore the Council have refused requests for an extension until the last
few days (It was slipped quietly into the Consultation details page after the 18th July with no
announcement and the Web landing page was not updated to make the public aware of the
change). This gives the impression that this was a consultation in name only and very little
time has been available for people to make alternative proposals. However the plan is
poorly put together and there are clear considerations and alternatives which should have
already been accommodated.
Significant areas of land to the South of Leamington Spa have been stated by the Council to
be undeliverable. This is incorrect.
Developing the land to the South of Leamington has significant advantages:
 The employment land is to the South and local employers are already saying they
need much more affordable housing in this area.
 The transport routes to M40 exist in this area and relatively affordable traffic
solutions will accommodate the expansion.
 The infrastructure already exists in this area, even to the point that traffic islands
have been built to take some of the new development!
MY KEY POINTS OF OBJECTION ARE
1. Local Amenity: The land proposed for development is a vital local amenity for
exercise and recreation; the recreational value of this land would be lost. The heavily
used footpaths make this element of greenbelt one of the most valued in the area. It
is for this reason there is such strong opposition.
2. These areas of greenbelt meet 4 of the 5 purposes of greenbelt land and should
therefore be protected from development. The Greenbelt Study undertaken by the
council is highly subjective and residents don't believe this is a sound basis for the
Preferred Plan.
3. Greenbelt land should not be developed because the Local Plan is governed by the
National Planning Policy Framework which states greenbelt should only be built on in
exceptional circumstances, and local residents believe exceptional circumstances
have not been demonstrated. In particular there is suitable land identified by the
Council to the East of Europa way and South of Heathcote that have not been
included in the local plan. Namely Grove Farm.
4. The apparent Council policy of spreading development around the county is not an
appropriate planning policy, but is rather a political policy and thus this greenbelt
land should not be built on.
5. There is further adequate land available around Radford Semele, this land has been
unnecessarily discounted by the Council due to the presence of gas mains, but this
land is viable in spite of the 100m exclusion zones by incorporating these zones into
part of the open space of a garden town.
6. The National Planning Policy Framework states that one purpose of greenbelt is to
prevent urban sprawl, the Preferred Option ignores this and causes sprawl, which is
compounded by Southward development of Kenilworth.
7. Even accepting the population and demand projections for housing the units
proposed to be built on the Green Belt land to Milverton Gardens (North of
Milvertion) could be deleted by omitting the 1400 over provision without causing a
deficit; residents believe this should be done.
8. Non greenbelt land that has not been included by the council is likely to have
planning permission granted on appeal from developers resulting in an overprovision
of land and needless development of this greenbelt.
9. The existing infrastructure is not appropriate to the new development, requiring a
£28 million relief road. The need to include such a massive undertaking invalidates
the argument that there is exceptional circumstances to build on the greenbelt. The
£28 million, even if raised from developers, is a waste of public money and will have
an adverse impact on the price of the houses and undermine the aims of affordable
homes
10. There is significantly better infrastructure in the South with access to the M40,
where development should therefore be placed.
11. There are inadequate employment facilities in the North of the town surrounding
the proposed development site and little evidence how the employment land, which
the Council propose to allocate, would be used. In contrast there is a good track
record and existing employers in the South of the town who chose to be locate close
to the M40. The plan must be evidence based and there is not enough evidence to
suggest there will be enough employment opportunity in the North of the town.
12. If additional housing is required for Coventry and Warwickshire Gateway then that
housing should be adjacent to the airport site to allow sustainable transport e.g.
cycling, avoid congestion, avoid coalescence, and justify exceptional circumstances.
If this were not possible then non-greenbelt land in the South should be released
capitalising on the M40 infrastructure and improved road layout near the site that
has already been identified by Councillors.
13. 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.
14. The preferred options plan states that it is vital to ensure that new housing is
affordable, construction on the greenbelt to the North of the town will not create
affordable housing. House prices are higher in the North of the town and the cost of
the relief road will be passed on by developers to new homeowners in the
development. Furthermore if development is focused in the South then an increase
in housing supply will ensure that the developers focus on delivering good quality
affordable homes. This is a simple supply and demand argument.
IN CONClUSION
I strongly urge you to reconsider your plans. There are no grounds in your evidence base to
justify building on any Green Belt Land at Milverton Gardens (North of Milvertion) and
Blackdown.

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I object to the lovely rolling countryside to the North of Leamington being permanently changed and therefore lost as we know it when there is a better alternative to build on less desirable land to the south of Leamington, ideally nearer to the M40 routeway.

This proposed development will impact the lovely existing amenity. Along with many others I regularly walk through the fields to Old Milverton. The proposal will replace some of these fields with urban sprawl stretching even closer to Kenilworth. It is a backward step for those interested in preserving the better quality green belt countryside for coming generations.

I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils's Preferred Options for the Local plan.

This land has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists.

The National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open.

The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land for ever. It
* Prevents the unrestricted sprawl of Leamington to the north
* Prevents the merging of Leamington and Kenilworth
* Helps safeguard the countryside from encroachment
* Helps preserve the setting and special character of Leamington (a historic town)
* Helps urban regeneration, by encouraging the recycling of derelict and other urban land
There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt.

The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land. Please reconsider your Preferred Options.

Further, the proposal to build a new northern relief road is utterly ludicrous. Thought should be given to upgrading the A452 from the M40 all the way to the Myton Road rather than looking to add one extra lane with a tidal flow type system. In a morning both before and during the rush hour the traffic queues all the way to the motorway because the existing road clearly has insufficient capacity to cope with the volume of cars seeking to drive into town. Such a scheme could also incorporate a display of public art on the roundabout where presently there is a rather unattractive area of landscaping thus creating a proper gateway that would enhance visitor experience to Royal Leamington Spa.

I would like to register my severe concerns about the proposed development of Old Milverton and Blackdown in Leamington Spa. I object to this development for the following reasons:

1. The land is incredibly valued by our local community and is used throughout the year by cyclists, dog walkers and joggers, including myself and my family and neighbours.

2. The National Planning Policy Framework states that the government attaches great importance to Greenbelt land as it prevents urban sprawl by keeping land permanently open. The main purposes of of the Greenbelt as set out by the NPPF are fulfilled by this land as:
- it prevents the unrestricted urban sprawl of Leamington to the north
- it prevents the merging of Leamington and Kenilworth
- it helps to safeguard the countryside from encroachment
- it preserves the setting and character of the historical town of Leamington

3. There are other sites which can be developed other than this cherished Greenbelt land. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, making the use of this land preferable.

4. The NPPF states that Greenbelt land should not be developed only in exceptional circumstances. As there are alternative sites this means that the development of Old Milverton and Blackdown will not be done in exceptional circumstances.

Aside from these practical reasons that I have set forth, I must also allow my own personal feelings to take precedent. I have been a citizen of Old Milverton for my entire life and I spent all of my childhood playing safely in the stunning Greenbelt land. I believe that due to this setting, I had a wholesome upbringing and am now a responsible and respected citizen. Your proposed plans will destroy the opportunity for future children to enjoy their childhood in a beautiful surrounding. While I understand the need for housing and employment opportunities, there are far more suitable and less destructive sites for development.

I urge you to reconsider your decision and please allow the Greenbelt land to remain intact.

I am writing to notify you that I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Council's Preferred Options for the Local Plan.

As a local resident who has lived in a number of parts of the Leamington area for a number of years, I believe that the Green Belt land earmarked as part of the Preferred Options has substantial recreational value to the local and indeed wider community.

As you will be aware, the area is enjoyed by many runners, riders, walkers and cyclists both within the immediate locality and beyond.

Above and beyond that, there are a significant number of families who use the area as an important means of getting quality family time together as well as exercise. Having such an area within central Leamington enables families to get out into the country without having to use transport to do so. This consequently reduces the carbon footprint of those families who would otherwise have to travel to nearby villages to do the same.

It is also an integral part of the character and attraction of the local area and has been pivotal in attracting a number of residents to the area. Many of those residents are business owners/senior managers within business whose presence in Leamington is of real value to the local business community and economy.

Further, visitors to the area often comment upon the approach into Leamington via Old Milverton, Northumberland Road and their charm. To develop the Greenbelt would in my view adversely impact upon the attraction of the town as a whole to visitors.

As I understand it, the National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts.

The Greenbelt in Old Milverton and Blackdown fulfils the five purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land.

It is my view that it:

1. Prevents the unrestricted sprawl of Leamington to the north
2. Prevents the merging of Leamington and Kenilworth
3. Helps safeguard the countryside from encroachment
4. Helps preserve the setting and special character of Leamington (a historic town)
5. Helps urban regeneration, by encouraging the recycling of derelict and other urban land

I understand that there are other sites which can be developed that are not in the Greenbelt and within the District.

These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Furthermore, employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt without the same overall impact on amenities and the character of the area.

The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites with existing infrastructure, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land.

Please reconsider your Preferred Options.

I am writing, within the consultation period, to object to the proposed development in Old Milverton and Blackdown contained in Warwick District Council's Preferred Options for the Local plan.

I live at the edge of one of the proposed areas and regularly walk in some of the areas proposed. En route I meet many local residents and people from a little further afield. It's clear to me that this land has great recreational value to the local community. This is so important that I feel I must draw your attention to some issues with the proposals that will need addressing.

Firstly, I understand that the National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open. It is also my understanding that the Greenbelt in Old Milverton and Blackdown fulfils the purposes of Greenbelt set out in the NPPF. It:
* prevents the unrestricted sprawl of Leamington Spa to the north
* prevents the merging of Leamington Spa and Kenilworth
* helps safeguard the countryside from encroachment
* helps preserve the setting and special character of Leamington Spa

Furthermore, the proposed development is contrary to the NPPF and goes against Warwick District Council's own study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value. 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. The development also puts Old Milverton at risk of being absorbed into Leamington Spa.

Second, The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. I understand that the special circumstances cited here are essentially that there is nowhere else for homes to be built. However I understand there are other sites which can be developed that are not in the Greenbelt. These sites, which are still available, are mainly to the south of Leamington, and were I believe identified in Warwick District Council's previous plan (the 2009 Core Strategy). The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities as well as existing out of town shopping facilities and good access to the town centre. Developing here will support the fifth purpose of Greenbelt in the NPPF, ie to help urban regeneration, recycling derelict/other urban land. As there are alternative sites, I doubt your ability to justify those exceptional circumstances that explicitly require the harm caused to the Greenbelt by the development to be outweighed by the benefit of the development.

Additionally, if the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road".

Third, Warwick District Council argues that land in the South of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. As far as I understand it, in planning matters consideration cannot be given to homeowners that fear loss of value to their property due to development. This is an important principle that means choices of where to develop are based on what is needed by the community and the balance between need of the housing, and the impact on the surrounding area. Well the same must be applied to the argument here. Warwick District Council cannot argue for one choice of development over another on the basis of developer profit.

Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the Greenbelt land at Old Milverton and Blackdown in the proposals

Please reconsider your Preferred Options and keep this land permanently open.

Having read the Local Plan for North leamington I would like to register my objections as follows:

* Areas selected for development are Green Belt Land
* According to the National Planning Policy Framework principles - Green Belt Land should only be used in exceptional circumstances
* There are no exceptional circumstances - previously identified non Green Belt land within the district is available, sufficient for future housing needs
* We need to protect our local countryside wherever possible to conserve an important amenity & avoid urban sprawl

I am writing to express my opposition to the District Council's plans to develop on Green Belt land as shown in their 2012 Preferred Options booklet.

My grounds for objecting are numerous but I'll focus this letter on three areas as follows:

1. National Planning Policy Framework (NPPF)

The fundamental aim of Green Belt policy as set out in the Government's NPPF is to prevent urban sprawl by keeping land permanently open.

The NPPF requires there to be "very special circumstances" for development in the Green Belt. It also requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the special circumstances are that there is nowhere else for the homes to be built. However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), 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 (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities south of Leamington as well as existing out of town shopping facilities and good access to the town centres of both Leamington and Warwick.

The previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council do not exist.

Warwick District Council argues that the land in the south of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Personally I'm shocked to think that consideration of the developers' "financial gain" rates so highly with the Council.


2. Proposed New Roads

Turning the A452 between Leamington and Kenilworth into dual carriageway will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the town centre. Building nearly 3,000 houses to the north of Leamington will simply increase the levels of congestion, whether there is a park and ride system in place or not.

A "Northern Relief Road" (budgeted cost £28m) is not required. Traffic flows tend to be north to south rather than east to west. If the proposed development does not go ahead this road will not be required anyway.

The proposed "Northern Relief Road" will need to be built across the flood plain near Saxon Mill and will violate an important historic corridor along the River Avon as evidenced by the number of archaeological finds reported over the years between Old Milverton and the A46 junction with Leek Wootton - exactly on the route of the proposed road. Not far away look what has been allowed to happen to Gaveston's Cross - since the A46 was built access is now virtually impossible. How can this be allowed to happen in a locality apparently proud of its historical heritage?

Alternatively, if development were concentrated in the south of Leamington, or to the west of Warwick, there is an existing road network (leading to the M40 and A46) that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road". Access to the railway stations at Leamington Spa and Warwick Parkway would also be much easier for commuters.



3. Farming, Wildlife and Recreation

The land between Old Milverton and Blackdown is prime fertile agricultural land that is actively farmed and brings with it several spin-off benefits.

First, the area is a haven for wildlife - foxes, pheasants, woodpeckers, bats, buzzards and kestrels as well as numerous garden birds, some of whom are reported by the RSPB to be in decline.

Second, the area provides much needed, and well used, country access to hikers, dog walkers and cyclists who routinely use the pathways across the fields from Northumberland Avenue through Old Milverton and on to the River Avon at Guy's Cliffe/Saxon Mill.

If the proposed HS2 High Speed Rail line does go ahead this would be an additional blow to those who value and enjoy the countryside between Leamington/Warwick and Kenilworth/Coventry. I believe Warwickshire is already been "forced" to pay too high a price through its loss of Green Belt countryside and that the District Council should be doing everything in its power to protect what is left for the benefit of both current residents and future generations.

I sincerely hope that the District Council reconsiders its "Preferred Options" for future development of the area, taking into account the views of its residents and fully adhering to the guidelines of the NPFF, rather than trying to "second guess" Government housing growth expectations and trying to tempt developers with "juicy" tracts of land stolen from the Green Belt.

We wish to express our fear and concerns over the proposed development planned for the green belt land in North Leamington. This surely must violate the conservation of the green belt - which once lost will never be regained and can only be detrimental to the whole community. Leamington and Kenilworth will each lose their own identity if sprawl is allowed and the two become merged.

Can the infrastructure really support such development in this area - roads, schools etc would further erode the surrounding countryside and also the cost would be prohibitive - the plans are surely unsustainable.

We therefore beg the council to seriously reconsider these proposals for the good of the countryside and maintain the quality of the environment and its people.

I am writing to protest strongly about the plan to develop green belt land in Blackdown and Old Milverton in Warwick District Council's preferred options for the local plan.
I have taken specialist legal and planning consultant advice in putting together my objections. I do understand the need for affordable housing in the area but I object to these being planned for the Blackdown and Old Milverton green belt land.
I object on a number of grounds:
I believe there are viable non-green belt alternatives as identified in the 2009 plan. There would seem to be no compelling planning reasons or 'exceptional circumstances' to justify the development of the green belt land in Blackdown and Old Milverton.
This green belt land fulfils the 5 purposes of green belt and in paragraph 16 of the government document ' Strategic gap and green belt policies in structure plans' clearly indicates that if there is a choice between green belt and green wedge then green belt is more important to preserve. So what I cannot understand is that if the choice is to either reduce the greenbelt land to the north of Leamington or reduce the green wedge in the south then the latter option must be the choice.
In the previous preferred options the green belt land at Blackdown was eliminated for further study ( point 7.32) and so Warwick District Council seem to have abandoned these conclusions from their own greenbelt study. In 2009 Warwick District Council conducted a substantial investigation and a public consultation and adopted a development plan for a similar number of houses which did not require ANY release of greenbelt. I have been told that at a meeting with councillors the reason for the change from this plan was given as 'everyone needs to share the pain' My barrister says this is not a legal planning argument!!
There are alternatives, mostly in the south of Leamington on non- green belt land.
The land just south of Heathcote could have 1200 houses and this is an area previously deemed suitable. The Radford Semele site could accommodate 565 houses instead of the 100 proposed. I am led to believe that the argument against developing Radford Semele to this level is the gas pipeline but I have had this looked at by a planning expert who believes that the pipes would still be far enough away to accommodate the higher level of houses.
It would seem to me to make much more sense to develop land to the south of Leamington that is nearer public transport links and closer to employment opportunities.
New housing to the north would significantly increase traffic on the A46 and A445 and would require a new expensive road to be built. Again I find it surprising when there are other alternatives.
There also seems to have been no consideration given to the loss of productive farming land that is planned to be sacrificed.
In summary, I strongly object to the development of greenbelt in Blackdown and Old Milverton as I believe there are more attractive alternatives to the south of Leamington which make much more sense from a planning perspective.
Having taken advice already, I feel so strongly that this plan is flawed and would be prepared to mount a legal challenge should it come to that.

I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils's Preferred Options for the Local plan.

1) The NPPF Guidelines

The National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open.

The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land for ever. It
* Prevents the unrestricted sprawl of Leamington to the north

* Prevents the merging of Leamington and Kenilworth

* Helps safeguard the countryside from encroachment

* Helps preserve the setting and special character of Leamington (a historic town)

* Helps urban regeneration, by encouraging the recycling of derelict and other urban land


The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land.

2) Recreation & Green Space Strategy
This land has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists and already fulfils the many ideals specified in the Green Space Strategy

I do not believe that the Social value of the green spaces for local residents has been objectively assessed through a specific public consultation following the advice in the "Draft Green Space Strategy". I, and new residents who have moved here in the past couple of years, have all mentioned the special area as a draw to live.

The greenbelt is a key draw for locals and visitors - groups strolling in hiking boots passed the house at weekends and the parking spaces at this end of Guys Cliffe are regularly occupied as it offers an excellent opportunity for recreational walking to other areas of North Leamington and beyond with through fields to the Saxon Mill (a 20 min walk vs a 10 min drive) and the historic links to Blacklow Hill

The fields are safe and convenient - also recommendations in the Green Space Strategy.

The paths are ready made corridors and networks that offer attractive access for pedestrians (as set out in 4.1.7 of the Green Space strategy).

Both the proposed building development and the "Northern Relief Road" would substantially reduce the amount of land that is available to be 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 land would detract from, rather than enhance its value.


3) The Projections that are driving the Preferred Options.

Basis for Development - Location and Population Requirements
From the information in the evidence base I do not see similar case for developing on Greenfield site and that the rational for the number of homes required and their location.

I hope that the National Planning Policy Framework is not just being used because it can rather than of necessity.


4) Alternative to Greenbelt
* There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt.

The "2009 Core Strategy" land south of Leamington (not in Green Belt), 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 (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.

Consideration of the developers' financial opportunity in developing Green Belt, rather than land available in South Leamington is not a "very special circumstance" to permit unnecessary development in the Green Belt.

The 2009 Core Strategy is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong.

5)The Proposed New Roads & Transport Strategy

A "Northern Relief Road" (budgeted cost £28m) is not required. Traffic flows tend to be north to south rather than east to 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 and to Coventry, Kenilworth or Stratford - which may have more attractive parking for motorists

Turning the A452 between Leamington and Kenilworth into dual carriage way will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centre. Building nearly 3000 houses north of Leamington will simply increase the congestion.
* That rail access is further away from the preferred options, with fuel prices and environmental concerns, building developments further from the local rail services seems counter intuitive and could result in more people chosing to use their cars to drive to stations - causing further congestion.

Please reconsider your Preferred Options.

I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils's Preferred
Options for the Local plan.

This land has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists.

The National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts
and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open.

The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should
remain as open Greenbelt land for ever. It
* prevents the unrestricted sprawl of Leamington to the north
* prevents the merging of Leamington and Kenilworth
* helps safeguard the countryside from encroachment
* helps preserve the setting and special character of Leamington (a historic town)
* helps urban regeneration, by encouraging the recycling of derelict and other urban land
There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of
Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities
and infrastructure already exists there, and this land should be used in preference to the Greenbelt.

The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative
sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in
Old Milverton and Blackdown and allowing development on this land.

Please reconsider your Preferred Options.

I write to object to the Warwick District Council Preferred Options, New Local Plan. I thought the detail prepared and presented was thorough, informative and clear. But as a result I it highlighted errors in decision making which strike me as proposing "policy based evidence" not proposing evidence based policy.

First, residents of Leamington Spa (indeed Warwickshire), take into account Green Belt when deciding where they can and aspire to live. To propose a plan which arbitrarily ignores current boundaries, redraws them and reconstructs the balance of Green Belt is poor planning (and negligent). The Green Belt is there for the opposite of your proposal - to protect urban sprawl. The current plan does not demonstrate evidence of "exceptional circumstances" necessary to build on Green Belt as required by the National Planning Policy Framework. Please answer why you have chosen to ignore land east of Europa Way and South of Heathcote towards Bishop Tachbrook which you previously identified as available, from the Preferred Options. Until sufficient and available sites outside the greenbelt have been used it is not valid to propose development on the greenbelt.

This leads to a second point of objection. Why does the council invent a need in the Preferred Options Plan of development on the greenbelt by generating housing requirement projections in excess of population and demand projections? It appears that the council is using the Preferred Options Plan as a trojan house for providing developers prime locations for development - regardless of necessity, as once the Local Plan is set it would be nearly impossible for developers to move into these valuable areas in the future if not included. Preferred Options based on Developer Preferences is not a Planning Policy, it's a political policy. Equally the proposal to develop "around" Leamington (many have used the term "spreading the pain" - I will too) is a political policy rather than respecting Planning laws and the National Planning Policy Framework.

Which brings into question the financial decisions of the plan. Why would the Preferred Options Plan generate a dependency / necessity on a £28m North Leamington relief road? You wouldn't need a relief road if you didn't plan to develop the Green Belt, and if you didn't need a relief road you wouldn't spend £28m of tax payers money unnecessarily. This is irresponsible, worse in the current climate when bins can only be emptied every 2 weeks.

I live in North Leamington, but equally have lived (and still own property) in South Leamington, I am a resident of Leamington Spa, not just Lillington Road - even I know, day to day that North Leamington infrastructure cannot support these proposals - even with a £28m relief road. The Local Council has ensured all supermarkets including a new Morrisons are in South Leamington / Emscote. Why generate another 2000+ households who need to traverse the town centre for their weekly shop? The train station, Motorway access, trading estates, industrial units are in South Leamington - why generate housing for 2000+ who need to traverse Leamington to access work, transport and services in these areas? Whilst I am interested in the Coventry development options for industry, there will be equally competitive plans from Coventry authorities to attract residents to South Coventry for these employment areas with which Leamington does not need to compete. You can argue that the plan will a new station in North Leamington, however the recent failure to open a station in a whole town without one (Kenilworth) makes this proposal a platitude to handle objections to the plan not a commitment to infrastructure. Finally, the sacrifice of even more Green Belt for the proposed Northern Relief Road is a further ingress into land which should not be scarred in the first place by the housing proposals.

Finally, the Local Plan proposals go against Planning Policies designed to protect the very aspects which make Leamington, Kenilworth, Warwick and many towns in the region unique, attractive and valuable in terms of quality of life and premium GDP generation. Planning policy to prevent urban sprawl must be taken into account. The planning authorities can act in a detailed enough way to prevent a Lillington Road neighbour developing on their property because it would negatively affect the unique sightline and character of the streetscape in the area - but the Local Plan proposes to blight the Green Belt, create urban sprawl and coalescence of the local towns of Leamington and Kenilworth and generate a traffic flow the infrastructure cannot hold - it seems hipocritical, and political rather than an evidence based plan respecting law and policy. All this whilst development opportunities outside the green belt, with better infrastructure capacity, transport options, access points and employment zones exist elsewhere and do not form part of the plan.

In summary, I object strongly as a resident of Leamington Spa, a taxpayer, a voter and an informed member of society to the Local Plan Preferred Options proposal. The Plan is flawed, creative and needs significant changes to stay within the policies set out at National Level, starting with the protection of the Green Belt. Once towns like Leamington Spa start to flout such policies and intents we set an example we cannot expect to put in reverse when future, more aggressive proposals come forward. The Council has a duty, empowered by the voter to protect Green Belt, protect taxpayer money and manage the uniqueness of the towns we live in until all viable alternatives can be evidenced as exhausted. The Local Plan Preferred Options is contradictory to this in too many respects and I demand it is revised.

I am writing to you to formally object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils' Preferred Options for the "Local plan".

I have a number of specific objection to both the basic nature and the scale of the Preferred Option as follows:

1) This land is used by my family and many of our friends for recreational activities - dog-walking, cycling, running, bird-watching etc. It is of huge value to the local community. My family use it virtually every day and meet people from all over Leamington when we do so. The impact the plan will have on people's general well-being cannot be underestimated.

2) This is Greenbelt land that serves a very specific purpose. I am sure that you must be aware the National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open. The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land for ever. These purposes are

* Prevents the unrestricted sprawl of Leamington to the north

* Prevents the merging of Leamington and Kenilworth

* Helps safeguard the countryside from encroachment

* Helps preserve the setting and special character of Leamington (a historic town)

* Helps urban regeneration, by encouraging the recycling of derelict and other urban land

3) There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt.

4) The building will completely change the nature of the small area of countryside left after the proposals are implemented, making it effectively unattractive and useless for any of its current users.

5) Communications links into the area will need significant changes and upgrades to cope with the massive increase in local traffic. The costs and general environmental impact for the areas surrounding will be considerable. The additional traffic will also make the current traffic issues seen on Kenilworth road into Leamington much worse - it will obviously be gridlock at busy times

6) Sites to the south of Leamington are significantly more suitable for building due to existing infrastructure and communications links. There is also a significant opportunity to develop "brownfield sites" rather than encroaching into Green Belt.

The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land.

Overall I also wonder at the integrity of the Council that has made this decision. It does not make any sense and the only reasons that logically come to mind are that there decision-making here has not been supported by the correct due diligence, or that there are some vested interests at play.

Please reconsider your Preferred Options.

I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils's Preferred Options for the Local plan.

This land has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists including myself and grandchildren.

The National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open.

The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land for ever. It
* Prevents the unrestricted sprawl of Leamington to the north
* Prevents the merging of Leamington and Kenilworth
* Helps safeguard the countryside from encroachment
* Helps preserve the setting and special character of Leamington (a historic town)
* Helps urban regeneration, by encouraging the recycling of derelict and other urban land
There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt.

The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land.

I wish to object most strongly to the proposed local plan for Warwick District. My main reasons for objection are as follows:

National Planning Policy Framework requires "Very Special Circumstances", and these are not met
* The fundamental aim of Greenbelt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.
* The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt. It also requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the special circumstances are that there is nowhere else for the homes to be built.
* However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), 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 (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.
* Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong.
* Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because 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 Green Belt should be maintained
* The proposals ignore Warwick District Council's study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value
* The National Planning Policy Framework (NPPF) 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. The Greenbelt land identified for development in the Preferred Option does carry out these purposes and its development would therefore be contrary to the NPPF.
* 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.

Recreation Value of Old Milverton and Blackdown should be maintained
* The land at Old Milverton and Blackdown is enjoyed by many walkers, runners, 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 be 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 land would detract from, rather than enhance its value.
* Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington.

Proposed New Roads would be inappropriate
* Turning the A452 between Leamington and Kenilworth into 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.
* Building nearly 3000 houses north of Leamington will simply increase the congestion.
* The dual carriage way will have a detrimental effect on the picturesque northern gateway to Leamington and southern gateway to Kenilworth.
* A "Northern Relief Road" (budgeted cost £28m) is not required. Traffic flows tend to be north to south rather than east to 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. If the development does not go ahead the road will not be required.
* 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.
* If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road".

New Out of Town Stores would be inappropriate
* The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area an attractive place to live. Further "out of town" shopping will take trade away from the Towns.

Loss of high quality Agricultural Land would be inappropriate
* There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton

Number of Homes included in the Forecasts is unnecessarily high
* Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the land at Old Milverton and Blackdown in the proposals.

I wish to register my objection to any plan to build on Green Belt land in or around North Leamington.
- Green Belt Land should not be developed when there is other more suitable land in the Leamington area available.
- This land must be protected for future generations to enjoy for exercise and recreation.
- WDC has not demonstrated 'exceptional circumstances' necessary to build on Green Belt land under NPPF.

I write to register my strong objection to the preferred Options Plan currently in Community Consultation.
There are in my opinion six areas of major planning weakness in the Preferred Options Plan, resulting in it being a meagre and insufficient document which does not propose any thoroughly supported substance.
1. The fundamental aim of Greenbelt policy in the Government's National Planning Policy Framework is to keep land permanently open to prevent urban sprawl. The 'very special circumstances' required by the NPPF to use Greenbelt land have not been stated in WDC's Preferred Options Plan. The NPPF requires the benefit of development to outweigh the harm caused to the Greenbelt. Where is this case? The previous Plan (2009 Core Strategy) is direct evidence that there are alternative areas for development, this proving the special circumstances put forward by WDC are wrong. WDC's argument that the land previously identified to the south of Leamington is less profitable to developers is not a 'very special circumstance' to permit unnecessary development in the Greenbelt.
2. The WDC study assigns high Greenbelt value to the land at Old Milverton and Blackdown, but this is ignored in the Preferred Options plan. These areas have high Amenity and Recreation use as green lungs for the population of Leamington, Warwick, Kenilworth and further afield in Warwick District and should not be sacrificed for the poorly defined 'green wedge' approach. Managed parkland is a very poor substitute for access to find agricultural countryside.
3. The Northern Relief Road is not required (budget c £28m) since traffic flows tend to be north to south. It is proposed across a flood plain with the associated high cost, violates the Avon nature corridor, and will if permitted provide a natural barrier to encourage further encroachment of the Greenbelt., coalescence of towns, and detract from the picturesque northern entry to Leamington and the southern entry to Kenilworth.. If built it will provide the residents of 3000 houses a quick route to get away form the jobs, shopping and econonic well being of Leamington and Kenilworth. The existing road network in south Leamington could be upgraded at considerably lower cost to meet the needs of development on the identified land there.
4. The out of town retail operations proposed are an inappropriate blow to the independent retailers in Leamington, Kenilworth and Warwick who make the area attractive to live in.
5. The use of a significant quantity of high quality agricultural land which is currently Greenbelt, is inappropriate in the world of rising food prices and a requirement to increase the green credentials of the economy.
6. There is a lack of clarity, a paucity of evidence and self inconsistency in the housing, jobs and homes model used for the Preferred Options Plan. The 1400 homes added as a buffer by WDC on top of the modelling are not evidence based. If they are removed, there is no need to include the land at Old Milverton and Blackdown. I would expect that a properly drawn plan should be numerically consistent, and not include a quantity of homes which appears to relate to a similar population increase i.e. about one person per home.
In summary, the Preferred Options lan is a very poor plan. It neither has the support of the community, nor has it adequate compliance to the National Planning Policy Framework. I commend the rapid creation of a suitably sound plan which has significant community support, to provide a relevant guide for the next decades of Warwick District.
To do this well, the current consultative process must be seen to be working, both in the actions of WDC at the conclusion of the process, and in the revised Plan which should emerge.

We are shocked and disturbed that there are plans to build a huge 'estate' on the beautiful Milverton /Blackdown green belt land.
We have seen many new builds go up around my own house since living in Milverton (26 years)and have never objected to any of them, but the size of the current plan would completely change the character of a huge area for thousands of current residents


My main reasons for objecting are:

1)It is and should remain an important green belt area. It is used widely by the local community for recreation; walking/running/cycling/wildlife enthusiasts/photographers etc. Other areas that are not set aside as green belt are available and should be considered. Can we not build more smaller developments on unused/little used urban and derelict sites?

2) The development will be the start of the 'merging' of Leamington and Kenilworth and Old Milverton, as Warwick is now merged with Leamington, leaving an ugly urban sprawl that will cause even more congestion which the towns cannot cope with. Even with a new dual carriageway.

3)The proposed businesses within the plan will take yet more customers from existing shops etc forcing even more closures of small businesses in the area. This is bound to have a detrimental effect to the look and feel of our beautiful, much visited town.

I wish to object most strongly to the proposed local plan for Warwick District. My main reasons for objection are as follows:

National Planning Policy Framework requires "Very Special Circumstances", and these are not met
* The fundamental aim of Greenbelt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.
* The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt. It also requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the special circumstances are that there is nowhere else for the homes to be built.
* However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), 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 (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.
* Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong.
* Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because 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 Green Belt should be maintained
* The proposals ignore Warwick District Council's study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value
* The National Planning Policy Framework (NPPF) 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. The Greenbelt land identified for development in the Preferred Option does carry out these purposes and its development would therefore be contrary to the NPPF.
* 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.

Recreation Value of Old Milverton and Blackdown should be maintained
* The land at Old Milverton and Blackdown is enjoyed by many walkers, runners, 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 be 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 land would detract from, rather than enhance its value.
* Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington.

Proposed New Roads would be inappropriate
* Turning the A452 between Leamington and Kenilworth into 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.
* Building nearly 3000 houses north of Leamington will simply increase the congestion.
* The dual carriage way will have a detrimental effect on the picturesque northern gateway to Leamington and southern gateway to Kenilworth.
* A "Northern Relief Road" (budgeted cost £28m) is not required. Traffic flows tend to be north to south rather than east to 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. If the development does not go ahead the road will not be required.
* 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.
* If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road".

New Out of Town Stores would be inappropriate
* The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area an attractive place to live. Further "out of town" shopping will take trade away from the Towns.

Loss of high quality Agricultural Land would be inappropriate
* There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton

Number of Homes included in the Forecasts is unnecessarily high
* Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the land at Old Milverton and Blackdown in the proposals.

We would like to state our objections to the proposed development of the north Leamington Green belt.

We feel that the suggested developments in North Leamington and Blackdown completely fly in the face of the government's policy that greenbelt land is to be protected at all costs unless there is a demonstration of 'exeptional circumstances'.

Leamington is a beautiful town with great diversity and beautiful parks and up until now good access to the countryside. We do not want Leamington to blend into other villages and towns to become a sprawling conurbation.
As soon as the greenbelt land is developed with the proposed bypass it is just giving the green light to develop ever further north and to join with Kenilworth etc.
There are very few easily accessible country walks from the centre of leamington and if you develop these for housing we will lose access to our beautiful countryside.
North Leamington is a very family orientated area and with a young family ourselves we chose to buy in this location 3years ago because of the access to the fields etc. We are most concerned about the traffic, pressure on open spaces for leisure activities, risks of cycling on the roads etc all increasing.

The land south of Leamington is already designated as white belt land and therefore has no reason not to be developed further than already proposed if deemed necessary to help with the need for more homes in the area. We do however question the need for the total number of new homes proposed especially as there are many flats unsold and flats above shops unoccupied as well as the rapid rate of closure of the high street shops suggesting lack of consumers.

Please don't ruin our town anymore. Your proposition is proprosterous and will destroy our beautiful countryside, the outlook of our town and the freedom of our families.

I am writing to object to the proposed changes to the Green Belt around North Leamington. I have lived in the area off Old Milverton Road since 1978 and during that time the Green Belt has been vigorously protected to prevent it spreading towards Kenilworth. From what I have read about the current proposal the encroachment into the Green Belt is both inappropriate and unjustified. I am advised that the proposals ignore Warwick District Council's own study of the Green Belt land at Old Milverton and Blackdown, which concluded that both areas had high Green Belt value. This land has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists.
It is my understanding that Green Belt land should only be put forward in Very Special Circumstances such as there are no alternative sites available for development. Surely the Council's main priority should be to help urban regeneration, by encouraging the recycling of derelict and other urban land?
It is also my understanding that there is land available in the south of Leamington which is not protected Green Belt and which has previously been identified for development but which has not been included in the current plan. Why is that? Blackdown and Old Milverton have always been primarily farming areas and employment requirements have gravitated to the south of town with its better employment prospects, its infrastructure and easier access to the motorway system. Adding more housing and employment facilities in North Leamington will only add to the existing overloading of the road system around the Kenilworth Road and building a Northern Relief Road will only push the congestion further into Leamington centre. The budgeted cost of the relief road is £28 million - can the town afford such a gamble with very scarce resources in these tight times?
It has been suggested that developers may make more profit from building in the north Leamington area and that has been a reason for the council to ignore its own policy to stop urban sprawl that would harm the open nature of the open countryside. Developers' profitability is not a Very Special Circumstance.
I believe that the Council's population projections are based upon the boom years and that the population growth now is unlikely to require the quantity of housing that is being suggested. The projected quantity of new housing required appears to have come about because the Council has included a buffer or contingency of 1400 houses. If that contingency is removed there would be no need to develop either Blackdown or Old Milverton.
Please reconsider your Preferred Options.

I write to you to formally object to the plans for the above development for many reasons. Firstly and most importantly, greenbelt land is protected from development and should only be used in exceptional circumstances. The current circumstances are not exceptional.
Secondly, other land that is not protected greenbelt land has been identified in the Heathcote area and this would seem to have been dismissed by the Council. This again would support the first point that the circumstances for the plans are not exceptional.
The site of the old Ford Factory had not been built upon for a considerable time and is now being developed into another supermarket, despite a major superstore being not a minutes walk away on the Shires retail park. Currently, there is 100,000 square feet available on that site for development.
Thirdly, the existence of a natural barrier between Leamington Spa and Kenilworth will be lost and increased traffic will lead to further damage to what will be left of the environment and the wildlife. The influx of new residents will place a strain on the Hospitals within the immediate area. It would also appear that no attention has been paid to the enormous cost of building roads and so on, when alternative sites already exist.
Finally, to return to the original point of the land proposed for development being greenbelt land. I asked my 8 year old daughter what she thought of the proposals, her answer was, 'Isn't greenbelt land forever?' That is exactly what this piece of land should remain, there for our children to benefit from and for generations to come.

I strongly object to the proposals on the grounds that the situation has not changed since the 2009 Core Strategy, so there cannot be any justification for these fundamental changes at this time or on greenbelt land when other options exist.

I am writing to object strongly to the proposed development of green belt land in Old Milverton and Blackdown.

As a resident of Leamington Spa for the past 68 years I have always appreciated the open space, recreational and exercising facilities created by green belt land.

I always thought that when an area was granted Green Belt status it was illegal for this status to be changed except for very exceptional circumstances. Looking at the area of Leamington as a whole I am surprised that the council have not seen fit to look at different areas where the impact of additional housing would not be so great.

The proposal as it stands would result in the urbanisation of Leamington and Kenilworth, a move which would result in these two towns losing their individual identities. It would also result in the communities of Old Milverton and Blackdown being lost.

I strongly urge the Council to reconsider their planned proposal.

For many decades the Greenbelt has provided a barrier to urban sprawl. To allow housing development at the above two sites would reduce the area for exercise and recreation i.e. walking to Saxon Mill. WDC has not demonstrated that there are 'exceptional circumstances' requiring these developments as there is non-Greenbelt land available; east of Europa Way and south of Heathcote which could be used for housing development without any infringement of Greenbelt land!!!!!