BASE HEADER
Blackdown
Gwrthwynebu
Preferred Options
ID sylw: 49921
Derbyniwyd: 12/11/2012
Ymatebydd: Dr Jakes Branton
This land has great recreational value to the local community.
This land fulfils the 5 purposes of Greenbelt as defined in NPPF.
There are other sites which can be developed that are not in the Green Belt. As such there are no exceptional circumstance to alter the Green Belt boundaries in old milverton and blackdown and allow development on this land.
I strongly 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 numerous 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 clearly 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.
Gwrthwynebu
Preferred Options
ID sylw: 49924
Derbyniwyd: 20/07/2012
Ymatebydd: Alison Bate
This land has great recreational value to the local community.
This land fulfils the 5 purposes of Greenbelt as defined in NPPF.
There are other sites which can be developed that are not in the Green Belt. As such there are no exceptional circumstance to alter the Green Belt boundaries in old milverton and blackdown and allow development on this land.
I wish to register my objection to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils's Preferred Options for the local plan.
I am sure you are aware, this land has great recreational value to the local community and is continually being utilised and enjoyed by many local runners, riders, walkers and cyclists.
You will equally know that the National Planning Policy Framework (NPPF) states how the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open. I wish you to reflect this in your building policy and note that 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 is essential in the
1) prevention of the unrestricted sprawl of Leamington to the north
2) prevention of Leamington and Kenilworth merging
3) safeguarding of the countryside from encroachment
4) preservation of the setting and special character of the historic town of Leamington
5) promotes urban regeneration by encouraginh the development of brown belt sites
I feel there are better sites which are better placed to absorb the devopment which don't encroach on the green belt and I would urge you to revisit your original proposals from 2009. These sites, which are mainly to the south of Leamington, have exisitng employment opportunities and infrastructure and it is this land which 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.
Furthermore, some of the land in Old Milverton and Blackdown is Grade 2 agricultural ground which must not be squandered.
Our Greenbelt must be protected and preserved. We owe it to ourselves and future generations.
Please, please reconsider your Preferred Options.
Gwrthwynebu
Preferred Options
ID sylw: 49926
Derbyniwyd: 20/07/2012
Ymatebydd: Carole Richardson
This land has great recreational value to the local community.
This land fulfils the 5 purposes of Greenbelt as defined in NPPF.
There are other sites which can be developed that are not in the Green Belt. As such there are no exceptional circumstance to alter the Green Belt boundaries in old milverton and blackdown and allow development on this land.
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
Gwrthwynebu
Preferred Options
ID sylw: 49929
Derbyniwyd: 20/07/2012
Ymatebydd: Aman Kandola
This land has great recreational value to the local community.
This land fulfils the 5 purposes of Greenbelt as defined in NPPF.
There are other sites which can be developed that are not in the Green Belt. As such there are no exceptional circumstance to alter the Green Belt boundaries in old milverton and blackdown and allow development on this land.
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.
Gwrthwynebu
Preferred Options
ID sylw: 49933
Derbyniwyd: 20/07/2012
Ymatebydd: Jon Wetherell
This land has great recreational value to the local community.
This land fulfils the 5 purposes of Greenbelt as defined in NPPF.
There are other sites which can be developed that are not in the Green Belt. As such there are no exceptional circumstance to alter the Green Belt boundaries in old milverton and blackdown and allow development on this land.
I would like to 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 the 7 employees of my business that is located in Old Milverton.
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.
Gwrthwynebu
Preferred Options
ID sylw: 49979
Derbyniwyd: 25/07/2012
Ymatebydd: E Lane
Weak 'special circumstances'.
Already made up minds where development will go and this is 'going through motions'.
Insufficient consideration given to alternatives.
Why change away from building south of Leamington?
Land between Cubbington and Lillington seems obvious site north of Leamington. Far enough from Offchurch to prevent coalesence.
Prime agricultural land.
Plots locally not in agricultural production - opposite Nuffield Hospital, two fields adjacent and Blackdown Nursing home. Two fields adjacent Management Training Centre surrounding A452 and Old Milverton Road roundabout possibilities. Could all be discreet developments with less impact.
Population demographic is shifting and sort of properties required are smaller for single people/small family units.
Large homes can be subdivided.
Lot of opposition.
Letter attached
Gwrthwynebu
Preferred Options
ID sylw: 49985
Derbyniwyd: 03/08/2012
Ymatebydd: Gallagher Estates
Asiant : Pegasus Group
Objects to allocation of land at Blackdown. The Plan fails to demonstrate exceptional circumstances for releasing this site from the Green Belt and the Joint Green Belt Study suggested this site was not suitable for consideration for development.
See attached documents
Gwrthwynebu
Preferred Options
ID sylw: 50037
Derbyniwyd: 25/07/2012
Ymatebydd: Ms Nicola Hunt
Object to development at Blackdown as the sites are located in Green Belt :
-will impact on the openness
-will constuture urban sprawl contrary to NPPF
-will lead to a significantly reduced gap between Leamington and Kenilworth
-exceptional circumstances have not bee justified
-there is a surplus provided for in the preferreed options - this is uneccessary
-provision to the nortbof Leaminton could be reduced by removing the over provision and looking at non-green belt locations (eg south of Harbury Lane)
-these site will increase traffic congestion on roads which are already congested.
-the proposed park and ride is likely to have little impact because of travle habits
-the coutryside in this area is high quality and is well used for recreation
-primary schools in the area are at capacity and new schools are unlikely to e developed rearly enough for new families to benefit from them.
Scanned representation
Gwrthwynebu
Preferred Options
ID sylw: 50050
Derbyniwyd: 20/07/2012
Ymatebydd: W and J Keeshan
Exceptional circumstances have not been demonstrated to remove land from Greenbelt.
There is highly suitable land available to south of Leamington that has not been allocated, as identified in the 2009 Core Strategy.
Ignores JGBS which concluded these areas had high green belt value. Land meets five purposes of greenebelt as defined in NPPF.
Reduce gap between Kenilworth and Leamington to 1.5m.
Land has huge recreation value.
Development of relief road would have a detrimental impact.
Would encourage Old Milverton to absorb into Leamington in future years.
Proposed new and widened roads in the area will have a detrimental impact. The northern relief road is expensive and unnecessary.
New retail operations will be a blow to existing retailers particularly in the town centres.
Loss of high quality agricultural land.
The Preferred options includes a 1400 buffer, land at old milverton and black can be removed.
Here are some suggested reasons why you might object to the proposals.
National Planning Policy Framework requires "Very Special Circumstances"
. 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
. 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
. 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
. 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
. 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 Agricultural Land
. 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
. 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.
Gwrthwynebu
Preferred Options
ID sylw: 50082
Derbyniwyd: 26/07/2012
Ymatebydd: Elaine Rumary
Opportunity to plan ahead for whole area taking account of natural terrain.
Shape should be dictated by contours, watercourses, old quarry and ancient grass road to precent flooding, reduce costs and make development sustainable.
Existing trees and new planting can be integral part of new landscape benefitting visual impact, health giving properties and as host to wildlife.
Historical links can be built in.
Essential for streams to be incorporated into development for site.
Attached proforma
Gwrthwynebu
Preferred Options
ID sylw: 50097
Derbyniwyd: 12/07/2012
Ymatebydd: Roger Speck
The site is too extensive and should be reduced in size.
Brownfield sites should be developed instead.
Objects to any development on Green Belt land and there should be no alteration to existing Green Belt boundaries.
Green Belt land is specifically set aside to prevent:
- urban sprawl;
- towns and villages merging; and
- development of the countryside.
See attached Response Form and Letter
Gwrthwynebu
Preferred Options
ID sylw: 50102
Derbyniwyd: 26/07/2012
Ymatebydd: Mr Alan Babington
It seems that the plan accounts for nearly 1400 extra homes above the number estimated to be necessary to meet towns population growth.
This over-calculation may be a 'safety net' on behalf of WDC but seems over cautious and would cause more building works, expense, disruption and needless use of land.
In particular, without the extra 1400 homes there would be no need to even contemplate building on presently designated Green Belt land north of Leamington in Old Milverton and Blackdown areas.
In detail, I object to green belt development in this area (Blackdown) as:
- It is against the NPPF and its greenbelt protection principles.
- There are more appropriate non-greenbelt sites - particularly land to the south of Leamington, which is better served by services and facilities
- This area is of high recreational and conservation value.
Please read below objections I wish to raise as part of the consultation period concerning the proposed development in old Milverton and Blackdown as detailed in Warwick District Council's 'Preferred Options' for the New Local plan.
a) Amount of new homes proposed:
Whereas I understand the need for the district council to have a plan in place for future growth and development in the warwick and leamington district, I have concerns about the number of new homes proposed in the 'preferred options' plan.
It seems that the plan accounts for nearly 1400 extra homes above the number estimated to be necessary to meet towns population growth.
This over-calculation may be a 'safety net' on behalf of WDC but seems over cautious and would cause more building works, expense, disruption and needless use of land.
In particular, without the extra 1400 homes there would be no need to even contemplate building on presently designated Green Belt land north of Leamington in Old Milverton and Blackdown areas.
I also object to the term and title of 'preferred options' - this makes members of the general public feel that the only options for development open to them 9and WDC) are those shown in the 'preferred options' plan and maps - there are other options not detailed fully although there seem to be other options mentioned briefly in the main report. there were also other areas of non-Green Belt land identified as suitable for development in the WDC's 2009 Core Strategy plan. these non-Green belt areas are still available for development - and even if not in the WDC's final plan, the non- Green Belt areas could still be ear marked for planning consent. The public need to clearly know ALL options and areas available for development.
Change to plan: Remove the extra 'safety net' of nearly 1400 homes from the plan.
Omit designated Green Belt sites from development plan.
Make all options more clear - highlighting ALL areas suitable for development to the public
b) Save our Green Belt land:
Although it is clear that WDC need to plan for housing developments for the future, I strongly object to proposed sites in the 'preferred options' in the areas of Old Milverton and Blackdown, north to and on the edge of the existing boundaries of Leamington Spa which is clearly presently designated Green Belt land. the Green belt areas north of Leamington have been identified by WDC in previous study as areas of high Green Belt value.
The National Planning policy framework (NPPF) identifies the Government's commitment to preserving our country's Green Belt areas. It states that the NPPF aims to protect communities and Green Belt and to help local people 'to protect local countryside and green space they value'. It is the responsibility of WDC to follow the guidelines set out by the NPPF; the 'preferred options' proposals do not do this.
As WDC must be fully aware, the main aims of Green Belt is to prevent urban sprawl by keeping designated areas open and clear from development.
The NPPF lists five purposes of Green Belt land and the Old Milverton and Blackdown Green Belt fits the purposes of at least four, if not all five, of these:
* To prevent unrestricted sprawl of Leamington to the north
* By preventing the merging of the towns of Leamington and Kenilworth; and keeping Old Milverton as a separate village community
* Safegurading the countryside from encroachment
* Preserving the historic and picturesque setting and character of Leamington and Kenilworth amongst scenic, protected countryside
* Helping urban regeneration, by encouraging the recycling of derelict and other urban land (this last bullet point would definitely be better addressed by WDC if the Green Belt is NOT built upon and other 'White land' is used and renovation of empty buildings in town)
If the Green Belt land north of Leamington is developed then it is likely that eventually the towns of Kenilworth and Leamington would meet and emerge; both losing their separate and individual characters.
My objection is valid as there are other sites for development available which are not green Belt land which would fulfil the needs of the planning proposals in regards to numbers of houses needed - these White land areas should all be utilised before development of Green belt land is ever considered. Non- Green Belt sites, many being south of Leamington, were clearly identified by WDC in their '2009 Core Strategy'.
As made clear by the NPPF, development of Green Belt land should only be proposed by a council under 'very special circumstances'. As WDC have already identified other non-Green Belt sites (although not all clearly publicised in this 'Preferred Option' plan) that are suitable for development, WDC do NOT have not given sufficient reasons or detailed 'exceptional circumstances' to validate their proposal to develop Green Belt land. WDC do not provide evidence that shows any superior benefit to the existing community of north Leamington should the Green Belt be developed. Therefore, WDC have not fulfilled the NPPF guidelines.
It is a matter of principle that WDC develops White land and preserves our Green Belt.
Change to plan: WDC to clearly identify ALL White land (non- green Belt) sites suitable for development (as in 2009 Core Strategy)
Development of south Leamington areas that are NOT Green Belt land and are suitable for development
Remove all proposals and suggestions to develop Green Belt land north of Leamington (Old Milverton and Blackdown areas)
c) Use of green Belt land:
The Green Belt land north of leamington in Old Milverton and Blackdown areas provide Leamington and Warwick residents with easy access to the countryside environment.
The Green Belt land is highly valued by local residents and visitors to the area who regularly use the pathways on the Green Belt land for recreational purposes; such as, walking, running, dog walking, bird watching, general relaxation. As a north Leamington resident for many years, i have often enjoyed using this land and strongly object to it being developed and destroyed.
The land is used regularly by many groups of the community of all ages. It is important to the health and well-being of residents, visitors and their dogs who are exercised there. It is a social place where people greet and talk to each other. To develop and destroy such areas would be a catastrophe.
The walks across the Green belt land are well known and well used by locals and visitors. If this land is destroyed then Leamington would lose an attractive asset which must only serve to encourage residents to stay living in the area, and new people to move to it. There is a lack of established open green space as it is - we should not destroy what we have.
Change to plan: Do NOT develop the Green belt land north of Leamington in Old Milverton and Blackdown areas as they are valued areas for recreation
WDC to protect our designated Green Belt land; ensuring provision for recreation on established Green Belt land
d) Conservation:
Linked to the above point, I strongly object to propsals in the 'Preferred options' plan to build on the Green Belt land north of Leamington as it is home to a wealth of wildlife and should therefore continue to be protected.
Development of green belt land would cause distruction of habitats and the environment for an abundance of wildlife and a wide variety of trees, wild flowers and plants. Development of this land would ruin this established natural environment. Even if green areas are left amongst new homes much of the wildlife (such as, bats, newts, herons and foxes) will leave the area because of noise and light pollution, lack of established habitat, dangers of changes in water availability, etc. Reduced Green Belt area will affect the movement of species across the land as they travel from place to place.
WDC is accountable for protecting the environment and habitats within the Green Belt land north of Leamington.
Change to plan: Omit proposals to develop Green belt land north of Leamington from the plan
WDC to protect and conserve Green Belt land as it is for future generations
e) Other available areas for development:
There are areas of land that are not Green belt which WDC has already identified as suitable for development - many sites are south of Leamington Spa as identified in the 2009 core strategy, and some (but not all) seen in plans in the current 'preferred proposals'
I object to proposals to build on green belt land in the old Milverton and Blackdown areas as I strongly feel that areas south of Leamington would be more suitable for development because:
* the areas south of Leamington are NOT Green Belt land
* they already have easy access to main roads and routes (such as, the M40 and A46) - infrastructure links that are capable of taking more traffic and space to develop further if needs be
* SHLAA identified that there is enough land in the south of town to devlop and suit the requirements for growth without having to develop Green belt areas north of the town
* there is a lot of existing employment areas and opportunities south of Leamington (business park, large shops, etc)
* there are large shops and supermarkets in that area which, if development was made north of Leamington, people would travel through town to get to causing lots of congestion - plans for growth in the retail area seem to be south of leamington - there is already a large shopping area south of Leamington which would not need as much development as building a new shopping area north of Leamington. if another out of town shopping area is built then more local and independent retailers within the town centre may suffer; shops close; leaving empty shop premises as an eye sore and so stop residents and visitors from wanting to shop in town or move to live in Leamington.
* developing key areas south of Leamington would reduce the need to spend millions of pounds developing infrastructure (roads, public transport, etc) north of town
* there are already established routes and public transport access south of Leamington which would be more easily revised and developed rather than creating brand new transport systems north of the town - development of the A452 between Leamington and Kenilworth would be costly and cause major disruption; traffic would still try to get through Leamington town centre in order for people to access the shops and amenities south of town.
* there are large open spaces in south area that are suitable for development of housing areas; land which is not Green belt
Although WDC has suggested that land south of Leamington may not be as attractive to developers as they might feel they'd make less profit - i strongly feel that this is an invalid reason to make proposals to build on green belt land because the profit made by developers should NOT be WDC's priority.
Change to plan: Concentrate on developing non- Green belt land south of Leamington and other non- green belt areas
WDC to stick to plans and areas identified in 2009 plan
Remove plans to develop Green Belt land north of Leamington in Old Milverton and Blackdown
WDC to include plans to enhance public transport south of Leamington
f) Affordable housing:
I am aware and agree that the WDC has to provide for the building of some homes that are 'affordable'. However, it is unclear in the documents why exactly WDC have proposed a 40% affordable housing plan. There needs to be consultation with the public about the need for 'affordable' housing.
Change to plan: consult with public in more detail about affordable housing needs.
Please accept the above points and opinions as my valid and firm objection to the proposal to develop the Green belt areas in Old Milverton and Blackdown, north of Leamington Spa; particularly as WDC has not produced sufficient evidence for 'very special circumstances' to develop and so erase those Green Belt sites. The WDC also needs to reconsider the planned numbers of houses and reduce their proposals by the extra nearly 1400 homes that have been added as a 'safety net' in their 'preferred option' plan.
Gwrthwynebu
Preferred Options
ID sylw: 50105
Derbyniwyd: 16/07/2012
Ymatebydd: Professor Christopher John Miller
Objects to the development of North Milverton and Blackdown as it would have a substantial and permanent effect on the local community.
The allocations do not accord with the NPPF that requires 'exceptional circumstances' to be established before green belt sites can be considered. It is stated that the required targets for housing growth can be realised by the use of alternative land (non-Green Belt) to the south of Leamington. There are also concerns that additional (new) infrastructure will be required to deliver the north Leam Green Belt sites that will require even more land being lost at this sensitive location and the eventual move towards coalescence with Kenilworth. Potential traffic problems associated with alterations to the Kenilworth road improvements are also stated as a cause for concern.
scanned form
Gwrthwynebu
Preferred Options
ID sylw: 50173
Derbyniwyd: 03/08/2012
Ymatebydd: Old Milverton & Blackdown JPC
Asiant : Hunter Page Planning
The entire site is located within the designated green belt. The site provides an important role in terms of the landscape setting to Blackdown Parish and urban Leamington. Moreover the SHLAA confirms that the site is of high landscape value and performs well in terms of green belt functions. The development of this site, would also result in a loss of Grade 2 agricultural land; require substantial infrastructure investment; lacks any connection with local employment land and is within a Water Sources Protection Zone. Notwithstanding its green belt status, the sustainability and deliverability of land at Blakedown is questionable.
See attachments
Gwrthwynebu
Preferred Options
ID sylw: 50200
Derbyniwyd: 26/07/2012
Ymatebydd: Mr Morrian Stretton
Natural beauty and green belt needs to be protected. It is productive agricultural land which will be lost and is a catchments areas for rainwater.
The area provides a barrier between Leamington and Kenilworth which should be retained. Its develoment will merge Leamington, Kenilworth and Coventry.
It is well used for recreation and is rich in wildlife.
It will lead to traffic congestion.
Out of town facilities in this area will destroy Leamington Town Centre.
The counryside should be protected by recycling derelict land.
Leamington needs to maintain it identity.
Scanned representation
Gwrthwynebu
Preferred Options
ID sylw: 50227
Derbyniwyd: 27/07/2012
Ymatebydd: Helen Edwards
Object to development at Blackdown. This is a beautiful green area and is well used for recreational activity. It is also against the NPPF which attaches great importance to the protection of greenbelt. This policy currently 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) and helps regeneration, by encouraging the recycling of derelict and other urban land. The proposal reduces the 'green lung' between Leamington and Kenilworth and there are also more appropriate sites to the south of Leamington where employment opportunities and infrastructure already exist.
See attachment.
Gwrthwynebu
Preferred Options
ID sylw: 50228
Derbyniwyd: 20/07/2012
Ymatebydd: Mr Alex Green
The land north of Leamington is used heavily for recreation and is highly valued for its beauty.
Green belt should be retained, nit built on especially as alternatives sites south of Leamington Spa are available where infrastructure is better.
Also the infrastructure requirements for the development will irrevocably damage Leamington and change its historic character. Road improvement (LNRR and dual carriageway are likely to lead to out of town stores and damage to the vitality of the Town Centre.
I am writing to protest against the recent proposal to develop Greenbelt land to the North of Leamington Spa. This is an area of outstanding beauty, which is enjoyed by my family. We regularly go for family walks in this area, and I am also a cyclist and a runner, and use this area for my recreational activities.
I was under the illusion that Greenbelt land could not be developed; but after carrying out research on this proposal, understand that it should only proceed if there is no other place for homes to be built. If it is necessary to build homes in the Leamington Spa area, strongly believe that the allocated area towards the south of the town would be better utilised.
Furthermore, the proposed infrastructure that would be required to facilitate the development to the North of Leamington Spa would have a irrecoverable damage to Leamington Spa, as an historic town. Leamington Spa town centre is enjoyed by locals and tourists alike, and a dual carriageway and possible northern relief road could lead to further out of town shopping developments, resulting in a detrimental effect on the town trade. Should further development be required, the infrastructure and employment opportunities are already in existence towards the south of town.
I would be grateful if you could reconsider your latest proposal, and kindly request that you DO NOT DEVELOP THE GREENBELT NORTH OF LEAMINGTON SPA.
Gwrthwynebu
Preferred Options
ID sylw: 50238
Derbyniwyd: 26/07/2012
Ymatebydd: Lenco Investments
Asiant : RPS Planning & Development
The site at Blackdown is also within the Green Belt and development in this location would also require significant contributions towards infrastructure and services, and the inclusion of employment to support the number of houses proposed. It is also within an area of water source protection and ground water vulnerability.
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
Gwrthwynebu
Preferred Options
ID sylw: 50334
Derbyniwyd: 27/07/2012
Ymatebydd: Mr Peter Robbins
Object to development at Blackdown:
- Very high amenity and recreational value, there is little alternative publicly open space in the area. Managed parkland is not a substitute for access to the countryside.
- Requires costly new high impact road infrastructure, which will also encourage further development in the green belt.The housing assessment fails to identify the footpath between Milverton and Old Milverton.
- Out of town retail operations / employment land will be another blow to independent retailers in Leamington and Kenilworth.
- Significant loss of agricultural land.
- Protected footpaths will be destroyed.
- Government policy under NPPF is very clear about protecting greenbelt and it's role in preventing urban sprawl.
- Ignores Warwick District Council's study of greenbelt land which concluded that Old Milverton and Blackdown have high greenbelt value.
Planning policy dictates that greenbelt must be more highly valued than green wedges therefore the Preferred Options document is flawed.
-There are no special circumstances demonstrated for developing the greenbelt - developers profit, political lobbying and that there is nowhere else for the homes to be built are not valid reasons
- There are suitable sites to the south of Leamington (land east of A452, Europa Way and South of Heathcote)and other locations provide better employment and infrastructure links. Land is also available around Radford Semele which has been unnecessarily discounted due to the presence of gas mains which could be developed in spite of the 100m exclusion zone.
- If Coventry gateway is the reason for developing housing north of Leamington we should still not be encouraging commuter towns but looking at housing solutions near the gateway.
- No evidence base to support the proposal or fully justify the rejection of sites south of Leamington.
- Suggested cost of the Northern relief road is likely to be higher than anticipated considering the ground over which the road must run and the bridges required. The road will not serve any purpose other than taking new homeowners to the A46.
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.
Gwrthwynebu
Preferred Options
ID sylw: 50342
Derbyniwyd: 25/06/2012
Ymatebydd: Mr Andrew Instone
Objects to Blackdown as it is considered that there are too many houses already in the vicinity
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Gwrthwynebu
Preferred Options
ID sylw: 50351
Derbyniwyd: 23/07/2012
Ymatebydd: Joanna Illingworth
The proposed development to the north of Warwick and Leamington is wrong in principle. The location doesn't have the infrastructure to support it, and will require the building of a new road and bridge over the Avon. An infrastructure project on this scale will then be used to justify further development, leading to the coalesence of communities - Warwick and Leek Wootton, Leamington, Hill Wootton and Kenilworth.
This flies in the face of national Green Belt policy and the declared aims of the Preferred Options. It also looks to be unsustainable with regards to transport.
The proposed development to the north of Warwick and Leamington is wrong in principle. The location doesn't have the infrastructure to support it, and will require the building of a new road and bridge over the Avon. An infrastructure project on this scale will then be used to justify further development, leading to the coalesence of communities - Warwick and Leek Wootton, Leamington, Hill Wootton and Kenilworth.
This flies in the face of national Green Belt policy and the declared aims of the Preferred Options. It also looks to be unsustainable with regards to transport.
Gwrthwynebu
Preferred Options
ID sylw: 50353
Derbyniwyd: 25/06/2012
Ymatebydd: Miss Jennifer Instone
Objects to the following sites the following sites as there are considered to be too many houses already in the vicinity of these proposed allocations.
Myton Gardens
South of Gallows Hill / Europa Way
Blackdown
Woodside Farm
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Gwrthwynebu
Preferred Options
ID sylw: 50355
Derbyniwyd: 26/07/2012
Ymatebydd: Mrs Pauline Pemberton
Objects to development north of Leamington in the Green Belt for the following reasons:-
The land development would be a loss of valuable amenity land used for exercise and recreation.
There are other non-green belt alternatives available therefore this area should not be used to accomodate future growth.
The Local Plan as set out is contrary to the NPPF and does not comply with the special circumstances required to enable consideration of development in the Green Belt.
The development will lead to coalescence of settlements with the loss of Old Milverton as a individual settlement. There are concerns that Leamington will ultimately merge with Kenilworth.
The current infrastructure will not be able to cope and future provisions (including the northern link road are too expensive and will divert funds from other more needed public investment).
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Gwrthwynebu
Preferred Options
ID sylw: 50356
Derbyniwyd: 06/07/2012
Ymatebydd: M.D and G.M Bond
Nifer y bobl: 2
Development in the Green Belt between Leamington and Kenilworth is opposed as follows:
- Result in a "Northern Relief Road" which has no purpose
- Be another blow to independent retailers with out of town shopping taking trade away from towns
-Not help traffic flows
-Not comply with the Government's National Planning Policy Framework for development in the Green Belt.
-Violate an important nature corridor
-Involve construction on the flood plain
-Loss of high quality agricultural land.
-Ignore the views of residents
Alternatives are available and workable and therefore "very special circumstances" cannot be justified
Re: Development of Green Belt between Kenilworth and Leamington Spa
We strongly oppose Warwick District Council's plan to destroy the green belt between Kenilworth and Leamington Spa with the development being planned.
We undernote details of our opposition:
The planned development will:
* Result in a "Northern Relief Road" which has no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns.
* Be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area attractive places to live. Further "Out of Town" shopping will take trade away from the Towns.
* Not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centres. Making it a dual carriage way will not help.
* Not comply with the Government's National Planning Policy Framework for development in the Green Belt.
* Violate an important nature corridor along the River Avon.
* Involve construction on the flood plain at Leek Wootton.
* Result in the loss of a significant amount of high quality agricultural land.
* Ignore the views of residents. In response to a previous consultation nearly 60% of respondents opposed development in the Green Belt
We understand that the main alternative sites are South of Leamington and that potential land has been identified and is we understand available. It is also easier to develop, there is the infra structure to support it, and it was in the 2009 Core Strategy plan which was the previous plan that was adopted by Wawick District Council. This previous plan did not involve development in the Green Belt North of Leamington.
We further understand that Warwick District Council emphasise the need to have an evidenced based plan to cater for the needs of the District to 2029. It states that if it is not a "sound plan" the Government Planning Inspector will reject it resulting in a "free for all" by developers. There will not be "a free for all", we understand that if the plan is rejected by the Planning Inspector development would be controlled by Warwick District Council which would still have to approve planning applications.
A "sound plan" does not require development in such an important area of Green Belt. We are informed that in 2009 Warwick District Council approved - A Core Plan for Strategic Growth until 2026 - which catered for more homes than the current plan and did not involve development of the Green Belt between Leamington and Kenilworth.
The Government's National Planning Policy Framework requires there to be "very special circumstances" for there to be development in the Green Belt and for the harm created to the Green Belt to be outweighed by the benefit of the development. Those special circumstances are apparently that there is nowhere else for the homes to be built. The previous plan is direct evidence that this is not the case.
We therefore strongly oppose the current proposals.
Gwrthwynebu
Preferred Options
ID sylw: 50357
Derbyniwyd: 25/08/2012
Ymatebydd: Robin and Shirley Adams
Nifer y bobl: 2
The development of housing and associated infrastructure planned for the precious green belt land to the north of the town and the construction of a new link road from the A452 to the A46 through Old Milverton, when better alternatives exist involving less cost to the environment and most probably also in monetary terms.
We wish to register our objection to the New Local Plan for the following reasons:
1. The development of housing and associated infrastructure planned for the precious green belt land to the north of the town and the construction of a new link road from the A452 to the A46 through Old Milverton, when better alternatives exist involving less cost to the environment and most probably also in monetary terms.
2. We accept that new housing is needed in the district though the estimates of the numbers required look well in excess of reality. We think it would be a tragedy for future generations if Green Belt land is lost when other good alternatives exist such as:
a) Land between Whitnash and Radford Semele and South of Leamington towards Bishop's Tachbrook
b) Hatton where good rail and road access already exists
3. The development does not appear to cater sufficiently for pedestrians and cyclists.
The plan gives the impression that it was started from the premise of taking the Green Belt land and all the verbiage in the plan then sets about trying to justify it.
We very much hope there will be a fundamental re-think before lasting damage is done to our local heritage, which future generations will deplore.
Gwrthwynebu
Preferred Options
ID sylw: 50358
Derbyniwyd: 20/07/2012
Ymatebydd: Mrs J. R. Limmape
Concerned that if the development on the Green Belt land to the North of Leamington goes ahead,the merging of Leamington and Kenilworth will become a reality.
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Gwrthwynebu
Preferred Options
ID sylw: 50359
Derbyniwyd: 20/07/2012
Ymatebydd: Heather Nicholls
With regard to the Green Belt land to the North of Leamington Spa. Green Belt is supposed to be exempt from development except in exceptional circumstances, thers are no apparent such circumstances. Furthermore there are white belt sites to the South, which were in the earlier plan Preferred Options. The area contains prime agricultural land, and currently provides a use to local residents for recreational activities.
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Gwrthwynebu
Preferred Options
ID sylw: 50360
Derbyniwyd: 26/07/2012
Ymatebydd: Mr Alan Knell
The proposed development to the Green Belt land North of Leamington must be considered unsound planning for the following reasons:
1.Development would destroy a key local amenity area.
2. Permits urban sprawl between Leamington and Kenilworth, creates a precedent.
3.Conflicts with 'garden suburb' character of Leamington.
4.Lack of adequate infrastructure.
5. 'Suitable and available' sites in South Leamington.
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Gwrthwynebu
Preferred Options
ID sylw: 50362
Derbyniwyd: 26/07/2012
Ymatebydd: Mrs Catherine Scott
Of those consulted, many people are shocked at the proposed development of the Green Belt to the North of Leamington. The NNPF requires very special circumstances for building in the Green Belt, furthermore there is non- Green Belt land available to the South of Leamington already identified. The development would have implications for the already busy roads. On sunny weekends, 80-90 people each day are known to use the Green Belt for recreational purposes. To compromise the Green Belt will diminish the town's attractiveness and uniqueness. To develop the Northern Greenbelt will eventually result in Leamington and Kenilworth being joined.
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Gwrthwynebu
Preferred Options
ID sylw: 50363
Derbyniwyd: 26/07/2012
Ymatebydd: Tina & John James
Nifer y bobl: 2
Strong objection to the proposed development of the Green Belt to the North of Leamington for the following reasons:
1. Alternative suitable land available that is not designated Green Belt.
2. There are no exceptional circumstances to override NPPF.
3. The Green Belt is one of few local amenities available for walking.
4. Grave risk of Leamington and Kenilworth merging in the future.
5. Infrastructure required to service Green Belt is more expensive, with more land required, than those areas not in the Green Belt.
6. Concern for the loss of beautiful countryside fringing the town.