Preferred Options

Object

Representation ID: 48865

Received: 30/07/2012

Respondent: Old Milverton & Blackdown JPC

The Parish Council objects to proposals to redraw the greenbelt boundary in Old Milverton to permit the construction of 1,980 dwellings, out of town shopping facilities, light industrial units, schools, park and ride and changes in the road network to cope with increased traffic resulting from this development. A large part of the north of the district is covered by greenbelt to prevent the coalescence of Leamington and Kenilworth into Coventry providing a 'green lung' between Leamington and Kenilworth, preserving the identities of these towns. Development is planned in this location despite the Preferred Option seeking to avoid coalescence. Future creeping development will allow Old Milverton to be subsumed by Leamington as the Relief Road will provide a natural boundary for future development. The original 2009 Core Strategy directed most development to the South of Leamington which there is capacity to grow the town sustainably and close to major employment. The NPPF includes the presumption in favour of sustainable development and that significant adverse impacts on the economic, social and environmental aspects of this should be avoided. Development in the greenbelt in this area would be contrary to this. The Preferred Options contravene the requirement in the NPPF for there to be 'very special circumstances' given the existence of alternative sites outside the greenbelt that are deliverable. The proposals ignore the Joint Greenbelt Study which concluded that land at Blackdown was not suitable for development and the March 2011 consultation in which 60% of respondents were against development in the greenbelt. The land provides a countryside environment close to the town centres and is enjoyed by many for walking, cycling and running etc. There is substantial public opposition not only from the two parishes directly affected but from further afield. Turning the A452 into a dual caridgeway will not help traffic flows and building more houses will increase congestion. The Relief road is not required as traffic flows tend to be north to south and will only serve to take new home owners in the area quickly onto the A46. There is an existing road network south of Leamington which could be upgraded at a considerably lower cost. Proposed out of town development will take trade away from town centres and be a blow to independent retailers detracting from the uniqueness of our towns detering visitors. There are two sites west of Warwick which are not in the greenbelt and the previous Core Strategy identified land to the west and east of Radford Semele but it is understood that this is rejected because of gas pipelines. However these do not rule out the entire site but prevent construction within 100m. Grove farm was also included in the previous Core Strategy but was rejected because it was considered that there would be too much development to the south, discussions with developers and consultants suggest these fears are unfounded. Local employers do not appear to have been consulted and a number of residents have expressed significant concern about the consultation process. It is felt that the Council is trying to defend its preferred options rather than presenting alternative options.

Object

Representation ID: 48878

Received: 30/07/2012

Respondent: Old Milverton & Blackdown JPC

The Parish Council objects to proposals to redraw the greenbelt boundary in Old Milverton to permit the construction of 1,980 dwellings, out of town shopping facilities, light industrial units, schools, park and ride and changes in the road network to cope with increased traffic resulting from this development. A large part of the north of the district is covered by greenbelt to prevent the coalescence of Leamington and Kenilworth into Coventry providing a 'green lung' between Leamington and Kenilworth, preserving the identities of these towns. Development is planned in this location despite the Preferred Option seeking to avoid coalescence. Future creeping development will allow Old Milverton to be subsumed by Leamington as the Relief Road will provide a natural boundary for future development. The original 2009 Core Strategy directed most development to the South of Leamington which there is capacity to grow the town sustainably and close to major employment. The NPPF includes the presumption in favour of sustainable development and that significant adverse impacts on the economic, social and environmental aspects of this should be avoided. Development in the greenbelt in this area would be contrary to this. The Preferred Options contravene the requirement in the NPPF for there to be 'very special circumstances' given the existence of alternative sites outside the greenbelt that are deliverable. The proposals ignore the Joint Greenbelt Study which concluded that land at Blackdown was not suitable for development and the March 2011 consultation in which 60% of respondents were against development in the greenbelt. The land provides a countryside environment close to the town centres and is enjoyed by many for walking, cycling and running etc. There is substantial public opposition not only from the two parishes directly affected but from further afield. Turning the A452 into a dual caridgeway will not help traffic flows and building more houses will increase congestion. The Relief road is not required as traffic flows tend to be north to south and will only serve to take new home owners in the area quickly onto the A46. There is an existing road network south of Leamington which could be upgraded at a considerably lower cost. Proposed out of town development will take trade away from town centres and be a blow to independent retailers detracting from the uniqueness of our towns detering visitors. There are two sites west of Warwick which are not in the greenbelt and the previous Core Strategy identified land to the west and east of Radford Semele but it is understood that this is rejected because of gas pipelines. However these do not rule out the entire site but prevent construction within 100m. Grove farm was also included in the previous Core Strategy but was rejected because it was considered that there would be too much development to the south, discussions with developers and consultants suggest these fears are unfounded. Local employers do not appear to have been consulted and a number of residents have expressed significant concern about the consultation process. It is felt that the Council is trying to defend its preferred options rather than presenting alternative options.

Object

Representation ID: 48879

Received: 30/07/2012

Respondent: Old Milverton & Blackdown JPC

The Parish Council objects to proposals to redraw the greenbelt boundary in Old Milverton to permit the construction of 1,980 dwellings, out of town shopping facilities, light industrial units, schools, park and ride and changes in the road network to cope with increased traffic resulting from this development. A large part of the north of the district is covered by greenbelt to prevent the coalescence of Leamington and Kenilworth into Coventry providing a 'green lung' between Leamington and Kenilworth, preserving the identities of these towns. Development is planned in this location despite the Preferred Option seeking to avoid coalescence. Future creeping development will allow Old Milverton to be subsumed by Leamington as the Relief Road will provide a natural boundary for future development. The original 2009 Core Strategy directed most development to the South of Leamington which there is capacity to grow the town sustainably and close to major employment. The NPPF includes the presumption in favour of sustainable development and that significant adverse impacts on the economic, social and environmental aspects of this should be avoided. Development in the greenbelt in this area would be contrary to this. The Preferred Options contravene the requirement in the NPPF for there to be 'very special circumstances' given the existence of alternative sites outside the greenbelt that are deliverable. The proposals ignore the Joint Greenbelt Study which concluded that land at Blackdown was not suitable for development and the March 2011 consultation in which 60% of respondents were against development in the greenbelt. The land provides a countryside environment close to the town centres and is enjoyed by many for walking, cycling and running etc. There is substantial public opposition not only from the two parishes directly affected but from further afield. Turning the A452 into a dual caridgeway will not help traffic flows and building more houses will increase congestion. The Relief road is not required as traffic flows tend to be north to south and will only serve to take new home owners in the area quickly onto the A46. There is an existing road network south of Leamington which could be upgraded at a considerably lower cost. Proposed out of town development will take trade away from town centres and be a blow to independent retailers detracting from the uniqueness of our towns detering visitors. There are two sites west of Warwick which are not in the greenbelt and the previous Core Strategy identified land to the west and east of Radford Semele but it is understood that this is rejected because of gas pipelines. However these do not rule out the entire site but prevent construction within 100m. Grove farm was also included in the previous Core Strategy but was rejected because it was considered that there would be too much development to the south, discussions with developers and consultants suggest these fears are unfounded. Local employers do not appear to have been consulted and a number of residents have expressed significant concern about the consultation process. It is felt that the Council is trying to defend its preferred options rather than presenting alternative options.

Object

Representation ID: 50172

Received: 03/08/2012

Respondent: Old Milverton & Blackdown JPC

Agent: Hunter Page Planning

The entire site is located within designated Green Belt. The site functions well in terms of Green Belt land and the submitted landscape appraisal confirms the sensitive landscape character of the site. As indicated in the SHLAA analysis for this site, the development of this site would result in the loss of Grade 2 agricultural land and potentially compromise the setting of the Leamington Spa Conservation Area. The SHLAA also highlights that development of the site would require substantial infrastructure improvements and suffers from a lack of employment opportunities - the suitability, sustainability and deliverability of the site is questionable.

Object

Representation ID: 50173

Received: 03/08/2012

Respondent: Old Milverton & Blackdown JPC

Agent: 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.

Object

Representation ID: 50198

Received: 03/08/2012

Respondent: Old Milverton & Blackdown JPC

Agent: Hunter Page Planning

Green Belt Planning Policy response:
- The allocation of 1980 dwellings to the north of Leamington clearly compromises the basic function of the Green Belt in this location, which is to prevent urban sprawl;
- There are alternative sites outside the green belt which can accommodate the proposed level of housing development suggested for north Leamington;
- The plan fails to demonstrate exceptional circumstances and merely sets out an objective to distribute growth across the district;
- The development of land north of Leamington flies in the face of the greenbelt objective to avoid the coalescence of settlements;
- The Preferred Options document is ignorant of the objectives of the green belt designation;
- The concentration of growth in certain locations to the south of Leamington is not unsustainable as there is a large amount of employment land, better infrastructure and accessibility to the town centre - indeed concerns with concentrating growth at south Leamington appear contrary to to the findings of the SHLAA;
- The SHLAA assessment of the preferred option housing sites indicated that this may lead to pressure to release further land for employment use - this type of use may be bulkier and larger in scale, having an even greater impact on the openness of the green belt;
- Although there are concerns about closing the gap between Warwick / Whitnash and Bishop's Tachbrook, there is no planning policy which would suggest that this is un-sustainable or unacceptable;
- Concerns about the ability of the market to deliver high levels of growth towards the south of Leamington are not supported.

Object

Representation ID: 50205

Received: 03/08/2012

Respondent: Old Milverton & Blackdown JPC

Agent: Hunter Page Planning

NPPF related comments:

- The allocation of major urban extensions and associated new road in the Green Belt to the north of Leamington is not the most sustainable option for the District when less environmentally sensitive alternative sites are available;
- The essential characteristics of green belt is their openness and their permanence - development to the north of Leamington would severely impact upon this character;
- The green belt sites to the north of Leamington are considered to function well with regard to: a) preventing urban sprawl; b) preventing the merging of Leamington and Kenilworth; c) safeguard the rural countryside from encroachment; d)ensuring the setting and special character of Leamington.
There are no exceptional circumstances which outweigh the harm caused by altering the Green Belt to the north of Leamington and allocating development in this location.

Object

Representation ID: 50209

Received: 03/08/2012

Respondent: Old Milverton & Blackdown JPC

Agent: Hunter Page Planning

Joint Green Belt Study (JGBS)

- The JGBS indicated that variations in the quality of land in the green belt and therefore some areas around the towns may be considered for development and therefore, removed from the green belt. It is fundamental to note that green belt is not a designation for landscape quality, but rather a functional planning designation for the purposes set out in the NPPF.
- The scoring system of the green-belt study is not consistent with the up-to-date guidance set out in the NPPF.
- However landscape character and quality is an important consideration and is addressed by the Cooper Partnership Landscape Appraisal.

Object

Representation ID: 50213

Received: 03/08/2012

Respondent: Old Milverton & Blackdown JPC

Agent: Hunter Page Planning

Post NPPF Green Belt Appeal Case:

The Inspector is unequivocol in his conclusions that the benefits of the proposed development, including benefits relating to housing delivery, sustainability, design, landscaping and accessibility do not amount to very special circumstances to develop in the greenbelt.

Object

Representation ID: 50223

Received: 03/08/2012

Respondent: Old Milverton & Blackdown JPC

Agent: Hunter Page Planning

Alternative housing sites available:

- Land to the south of Leamington is not designated green belt, nor within any nationally designated area of landscape or environmental protection. It also has potentially better services and infrastructure. Land is available in this area (Lower Heathcote Farm) which is currently being promoted for development and could easy accommodate the scale of development proposed for land north of Milverton and at Blackdown.
- There does not appear to be any robust evidence to support suggestions that there are insurmountable deficiencies with south Leamington to accommodate an additional 1980 dwellings.
- The concentration of growth in South Leamington was identified in the previous Core Strategy Preferred Option (now abandoned). There does not appear to be any relevant justification as to why this spatial vision was abandoned as spatial planning considerations and planning constraints of Leamington / Warwick have not changed.
- It is contended that there are other sites on the eastern and western sides of the settlement that have not been properly assessed or considered in the Preferred Option. All potential and sequentially preferable (non-greenbelt) growth options need to be exhuasted before major development in the greenbelt is considered further.