South Warwickshire Local Plan – Update March 2024

The Green Belt around North Leamington is a valued open space.

In surveys residents say that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health.  It is easily accessible on foot from North Leamington so many people can access the public rights of way across the fields.  Use of these footpaths increased markedly during lockdown and these high levels of use continue today.  The agricultural land   continues to provide rural employment and undergo diversification of farming techniques.  Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever.

The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply.

Recent Government policy has stated that farming and food production make an important contribution to sustainable development.  The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa.  The land making up these sites is, therefore, considered to be a scarce resource of high value for sustainable food production.  The Government seeks to protect against the loss of such land from non-agricultural development.  The National Planning Policy Framework is clear that “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality”; a policy which will continue to grow in significance as the increasing cost of imported wheat and grain drives up domestic food production needs.

The proposals would lead to a merging of the boundaries of Kenilworth and Leamington.

Developing the North Leamington Green Belt would significantly reduce the belt of land that separates Kenilworth from Leamington, particularly in view of the Thickthorn housing development now underway and other recent housing and commercial developments in the area. The proximity of HS2 developments in neighbouring parishes is also strongly felt. Despite this, numerous other sites along the A452 have been put forward in the Call for Sites. Once land is removed from the Green Belt for development this cannot be undone and a precedent is set which makes it easier for adjoining swathes of land to be built on.  Building more new houses on the outskirts of Leamington will exacerbate the current high levels of traffic congestion which has come with the new housing developments south of the town. The original layout of the town and the subsequent development in the 19th and 20th centuries precludes the construction of major new cross town access routes.  The joint Green Belt study of 2015 highlights the important contribution to preventing the merging of Leamington, Kenilworth and Coventry that this piece of the countryside (Broad Area 3) makes by preventing urban sprawl, safeguarding the countryside and preserving the special character of these historic towns.

Similar proposals were rejected less than six years ago.

The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91).  It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa.  It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201).  This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat.  Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017.  If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made.

It is not in line with current Government policy.

The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (See letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints” (see letter above).  The utility of the Green Belt around North Leamington is a genuine constraint on development.

It skews development away from affordable housing in the areas where people work.

The Government has also made a “brownfield first” pledge (see letter above) which should inform the way that the District Councils respond to unmet housing need in other authorities.  Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work.  The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit.

The process is flawed because all five options presume Green Belt development without acknowledging the significant constraints involved.

The Issues and Options consultation puts forward five “spatial growth options”.  All of these would involve development of some areas of Warwickshire’s Green Belt, and all of them suggest North Leamington Green Belt as an area of ‘significant urban extension’.  This is in line with the outcomes from a series of spatial growth workshops which revealed a preference to promote development at scale within the Green Belt. However the premise of these workshops is grossly flawed. The proposition that Green Belt serves no legitimate function and can be ‘switched off’ as an academic exercise flies in the face of the significant contributions that Warwick District Council and Stratford District Council have themselves noted that Green Belt designation makes.

The Green Belt puts major restrictions – for good reason – on what can be built where.  The  spatial growth workshops did explore growth options where Green Belt development was not permitted. However none of these feature in the current five spatial growth options.  This is contrary to recent Government announcements, the 2015 greenbelt review and the 2017 response by the Planning Inspector.

The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. 

These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation.  Both state that development at these locations would be “unlikely to lead to coalescence of settlements”.  However any development here would subsume Old Milverton and Blackdown into Leamington.  It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby.  This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”.  If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development.  Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area.  We think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development.