Full text:
Although it is pleased that the land of the Binswood Ex Serviceman's Allotment Society (The Society) is now excluded from the proposed devlopment land, the Society has a number of concerns about the designation of part of the North Leamington Green Belt as a site allocated for housing or mixed use development. The Society is particularly concerned about the land 'North of Milverton' but a number of the arguments set out below apply equally to the Blackdown' site.
At Paragraph 80 of the Framework, it is stated that Green Belt serves five purposes;
* to check the unrestricted sprawl of large built up areas;
* to prevent neighbouring towns merging into one another
* to assist in safeguarding the country side from encroachment;
* to preserve the setting and special character of historic town's; and
* to assist in urban regeneration.
The Green Belt between Leamington and Coventry and Kenilworth was established in 1975 as part of the West Midlands Green belt to prevent urban sprawl and the coalescence of urban areas. These objectives remain as the principal purposes of Green Belt in the Framework
At paragraph 83 of the National Planning Policy Framework, states that;
'Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan'.
The principal of change in exceptional circumstances is carried forward from PPG 2. A key statement in PPG 2 is that
'the essential characteristic of green belts is their permanence. Green belts are not intended to appear and disappear at the drop of a hat. 'Once the general extent of a green belt has been approved it should be altered only in exceptional circumstances'. Even the detailed boundaries of the green belt should only rarely be changed'.
As established Green Belt, the Association considers that the second sentence of paragraph 83 applies. and has seen no evidence in the Consultation documents that demonstrate such exceptional circumstances.
Any encroachment into the Green Belt is considered to render it less effective in achieving its purpose, in that it reduces the size of the buffer and it creates a precedent for its continuing attrition. It seems anomalous that we should be making the case for safeguarding to the body which should be doing its utmost to ensure safeguarding.
At paragraph 84 of the National Planning Policy Framework, it is stated that in reviewing Green Belt boundaries, 'authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban area inside the Green Belt boundary towards town and villages inset within the Green Belt or toward locations beyond the outer Green Belt boundary.
The Consultation Document, at 7.19, states that the sustainability appraisal of the options showed that focusing development outside the Green Belt had clear advantages associated with the provision of sustainable transport options and reducing the need to travel. Thus the proposed allocation of Green Belt land fails on the review criteria of paragraph 84 of the Framework. Equally it is clear that development of non-Green Belt land to the South of Leamington does meet the review criteria both in offering more sustainable transport options and in using locations outside the Green Belt.
Of the 12 core land-use planning principles set out in paragraph 17 of the Framework, the first states that planning should empower local people to shape their surroundings. The consultation into the core strategy paper elicited between 700 and 750 responses. Some 40 percent of respondents were against development in North Leamington and some 25 percent against development North of Milverton. The Council response, in perpetuating allocation of these sites, could scarcely be construed as empowering local people to shape their surroundings.
As part of the work on the BLAST response to the Options for Growth, a Bio-Diversity Survey was carried out by the Ecology Unit of Warwickshire County Council. This demonstrated that the allotment sites contained great ecological diversity including the rare and protected European Crested Newt.
An earlier ecological survey prepared by The Habitat Biodiversity Audit Partnership on behalf of the District Council describes the habitat of the land North of Milverton as follows
Although arable dominates this parcel of land there are numerous species of rich mature hedgerows which are valuable to many species as well as being important landscape features. The hedgerows create a network of wildlife corridors through the intensively-farmed landscape and help connect the other important habitats such as the river, strips of woodland, ponds, grasslands and wetlands.
The Society is proud of the diversity of its site; it encourages members to have regard for ecology in the way they work their plots and is deliberately not over vigorous in the maintenance of hedges and verges so as to sustain wildlife. The network of wildlife corridors outlined above is of great significance in the continuing viability of diversity on the allotments and a significant part of the network will be destroyed by the development of the Land North of Milverton. Wildlife generally is at risk from a variety of factors, most notably destruction of habitat and global warming. At PO 10, Built Environment, the Council sets out as an objective 'to protect, enhance and link the natural environment', it patently will fail to do so if it continues to promote development North of Milverton.
