No

ID sylw: 107251

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

It is not clear what evidence base is relied upon to justify the exceptional circumstances to review and release Green Belt. This will need to be published and subject to testing consistent with the NPPF.

Other

ID sylw: 107256

Derbyniwyd: 07/03/2025

Ymatebydd: R. Adams & Sons R. Adams & Sons

Asiant : Iceni Projects

Whilst the approach to reviewing Green Belt boundaries is supported, the policy must be more explicit in its recognition that Green Belt development must take place to accommodate housing and employment need. Furthermore, the policy must be explicit in its support for exceptions to Green Belt development, including agricultural buildings use (as outlined within the NPPF), and within policy CS.10 of Stratford’s adopted Core Strategy.
Notwithstanding, the current draft plan makes no policy allowance for Grey Belt land (Annex 2 of NPPF 2024). Thus, additional evidence gathering exercises must be undertaken to make identify Grey Belt sites. This will be critical in meeting South Warwickshire’s identified employment need.

Other

ID sylw: 107353

Derbyniwyd: 06/03/2025

Ymatebydd: National Trust

Green Belt – We note the changing position in terms of Green Belt as set out in the revised NPPF (December 2024), which has opened up the consideration of land within the Green Belt as grey belt and being suitable for development where such land meets the “golden rules”. We understand that a Call for Sites and there is the intention to review villages washed over by the Green Belt designation to identify whether they would be appropriate for infilling. The National Trust are supportive of a plan-led system and accordingly are pleased to hear that further consideration of the Green Belt is going to be taking place, and that a sequential approach is likely to be taken forwards.
The Regional Park concept that the National Trust is developing in the north west Stratford on Avon area and covering Bromsgrove and south west Solihull lies in the Green Belt. We consider that the regional park presents the opportunity to enhance Green Belt policy by promoting the multi-functional purpose of the Green Belt in terms of outdoor recreation which can be enhanced through improved access to open space in the regional park area but also requiring any development which takes place in the Green Belt to secure the highest quality green infrastructure that would connect into the regional park and hold developers to greater account in respect of how development can contribute to the regional park within the area, and the prevailing character of the area, which will also deliver public benefits beyond addressing the housing needs of the Housing Market Area.
We would be keen to discuss the contribution that the Regional Park could make towards achieving a number of objectives set out within the South Warwickshire Local Plan Preferred Options consultation with Officers, including relating to Green Belt, open space, biodiversity, health and wellbeing, and equitable access to nature.
In terms of our specific land interests within South Warwickshire, Packwood House, Baddesley Clinton and Coughton Court are all located in the Green Belt. The designation of Green Belt at these locations contributes towards the preservation of the special character of the places we care for however we are mindful of our visitor business at these properties, with the need to ensure that our visitor facilities are fit for purpose and able to preserve and enhance the heritage assets we are responsible for. We therefore seek to ensure that any development that is proposed on site accords with national Green Belt policy.

Other

ID sylw: 107381

Derbyniwyd: 04/03/2025

Ymatebydd: Mr & Mrs - Blackhurst

Asiant : Frampton Town Planning

Given the sites credentials and access to existing services and public transport, there are clear sustainability benefits to utilising this site, and releasing land at Arden Lodge, Station Lane, Kingswood, from the Green Belt for residential development, should the above criteria be met.

Other

ID sylw: 107512

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We support the Council’s approach to undertaking a Green Belt review as an integral part of the evidence base underpinning the SWLP.
We do however object to any sequential approach to Green Belt release, where this seeks to allocate non-Green Belt sites before considering Green Belt release. This is a wholly inappropriate approach, it does not in accordance with the NPPF which has no such sequential approach to Green Belt release, and risks bringing forward a plan which is not founded on robust broader sustainability principles. For example, applying a sequential approach would close off significant parts of the main towns of Stratford, Warwick, Leamington Spa and Kenilworth. It would also make addressing the duty to co-operate far more difficult since a sequential approach would effectively push any housing requirements meeting the two HMA’s further south away from the HMA areas which housing is intended to serve.

Other

ID sylw: 107567

Derbyniwyd: 04/03/2025

Ymatebydd: James Bushell

Asiant : Frampton Town Planning

Given the sites ( Land north of Old Warwick Road, Kingswood )credentials and access to existing services and public transport, there are clear sustainability benefits to utilising this site, and releasing it from the Green Belt
for residential development, should the above criteria be met.

Other

ID sylw: 107583

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

In terms of safeguarded land the draft policy direction states:

"Areas of existing safeguarded land such as the land at Westwood Heath designated
in the adopted Warwick District Local Plan will also need to be revisited to determine
whether they are suitable for development, based on the latest available evidence."

The sequential approach is supported, and accords with national policy. In terms of the
safeguarded Land at Westwood Heath, this now needs to be considered in the round with
other options being put forward and in line with the updated evidence base. Coventry City
Council, through its Regulation 19 Plan has not identified a future shortfall in terms of
housing need and whilst this remains yet to be examined it seems unnecessary to retain
safeguarded land in this location when through the sequential approach other locations
would be more appropriate. This is also significant in terms of the conclusions of the
Sustainability Appraisal which identifies the SG01 area (which neighbours the safeguarded
land) as scoring especially poorly in terms of biodiversity, landscape, natural resources and
pollution. Development should be steered elsewhere and the safeguarded land should be
returned to the Green Belt.

Other

ID sylw: 107601

Derbyniwyd: 07/03/2025

Ymatebydd: National Highways

We have limited comments to provide in relation to this Draft Policy Direction although
welcome the approach to make full use of suitable urban brownfield land before
alternative land is considered.

Other

ID sylw: 107697

Derbyniwyd: 04/03/2025

Ymatebydd: Pete Frteeman

Unlike today, Green Belt policy was put in place way back when politicians and planners possessed credibility, vision and common sense and such areas were designate with good reason. I don’t care what terms have been invented by planners to justify the desecration of the Green Belt. It simply should not happen in any form whatsoever (.)
My own experience is coloured by the "Shock headed" planning proposals for Green Lane & Kings Hill with its Coventry/Warwickshire boundary fiddling and politics! [redacted]! ........ It's Green Belt so leave it alone!

Yes

ID sylw: 107846

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey welcomes the consideration of Green Belt release through the emerging plan and agrees that many of the most sustainable locations in South Warwickshire are within the Green Belt, including areas around key railway stations, such as Warwick Parkway.

The latter part of the Draft Policy Direction also comments on the potential for the identification of additional safeguarded sites to meet longer term needs. Although this may be appropriate in principle, as set out in respect of Draft Policy Direction 1, there is a substantial amount of need to meet at the current time, as such, sites that are assessed as deliverable, should be considered for allocation in this plan.
Land to the north east of Hampton Magna (Appendix 1 of this note) is assessed as two parcels by the Green Belt Review, identified as:
• HMG1 - comprising the northern part of the site south of the railway line
• HMG2 - comprising the southern extent, to the immediate east of the settlement of Hampton Magna.
Overall HMG1-Weak HMG2-Weak
Considering the above assessment, and inherent sustainability of the site, being in close proximity to Warwick Parkway railway station and being otherwise unconstrained, this site is considered to represent an opportunity to meet a proportion of the additional needs identified for South Warwickshire. It should be removed from the Green Belt and proposed for allocation to deliver new homes.

Other

ID sylw: 107903

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

As the SWAs will be aware, the NPPF is clear that:
“Once established, Green Belt boundaries should only be altered where exceptional
circumstances are fully evidenced and justified through the preparation or updating of
plans.” (Para 145)
2.78 It goes on to state that:
“Exceptional circumstances in this context include, but are not limited to, instances where
an authority cannot meet its identified need for homes, commercial or other development
through other means. If that is the case, authorities should review Green Belt boundaries
in accordance with the policies in this Framework and propose alterations to meet these
needs in full, unless the review provides clear evidence that doing so would fundamentally
undermine the purposes (taken together) of the remaining Green Belt, when considered
across the area of the plan” (Para 146)
2.79 The NPPF further sets out a sequential approach required to be demonstrated prior to
concluding that ‘exceptional circumstances’ exist. This includes utilising brownfield land, optimising densities and engaging with neighbouring authorities to assist in meeting needs
(Paragraph 147). Therefore, when considering the sequential approach required to
demonstrate whether ‘exceptional circumstances’, it is clear that there is insufficient
brownfield land across South Warwickshire, and that optimising densities is also unlikely to
meet the SWA’s needs in full.
2.80 It is also unlikely that other authorities within the C&WHMA are able to assist in meeting
the SWA’s needs, as they are equally as constrained by Green Belt or tight administrative
boundaries. When taken together and given the scale of the SWA’s housing needs under the
new SM, it is clear that ‘exceptional circumstances’ can be demonstrated and Green Belt
release should be explored within the SWLP.
2.81 It is the case however, that land that is capable of delivering sustainable development
should be the first choice in the selection of locations for new development. To this end,
Terra strongly support the SWLP identifying potential SGLs including land within and
outside of the Green Belt – particular land around SG14- East of Gaydon. Importantly, in
exercising policy choice regarding the section of appropriate sites and taking into account
the designation of land, SGO14- East of Gaydon falls entirely outside if the Green Belt, and
is not subject to any significant land use designation that would preclude development from
coming forward.
2.82 In addition, the settlement is well located in order for residents to access a range of key
local amenities and facilities, both Gaydon and Lighthorne Heath, and would also benefit
from the economic growth planned at JLR, including significant safeguarded land for future
jobs growth.

Other

ID sylw: 107914

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey welcomes the consideration of Green Belt release through the emerging plan and agrees that many of the most sustainable locations in South Warwickshire are within the Green Belt.
Having regard to the evidence base for the emerging plan, the Green Belt Review Stage 1 Report (September 2024) sets out an “objective, evidence-based and independent assessment of how the parts of the West Midlands Green Belt that fall within South Warwickshire contribute to the five purposes of Green Belt set out in the NPPF”. More detailed, site specific, assessment work is anticipated to inform later stages of plan making and we reserve the right to comment on the evidence base documents in due course.
Overall HOH2-Weak
As such, considering the above assessment, and inherent sustainability of the site, being in close proximity to Warwick Parkway railway station and being otherwise unconstrained, this site is considered to represent an opportunity to meet a proportion of the additional needs identified for South Warwickshire. It should be removed from the Green Belt and proposed for allocation to deliver new homes.
However, notwithstanding the comments as per the above, should this be discounted from Green Belt release by this plan, as a minimum, it should be safeguarded for future development. In addition, should a Grey Belt list be developed by the Councils, this site should be included.

Yes

ID sylw: 107921

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Draft Policy Direction 7 states that:
“The SWLP will take a sequential approach to allocating strategic areas of growth and new settlements. Further evidence will be gathered on the relative sustainability
of each of these areas. Some of this evidence will come from the Stage 2 Green Belt review, regarding the contribution an area makes to Green Belt purposes, and the impact on the wider Green Belt if an area was to be released. This additional evidence will enable a considered assessment of whether there are sufficient
sustainable non-Green Belt locations to accommodate South Warwickshire’s housing and employment land needs. If so, then there will be no requirement to release land from the Green Belt. However, if there are clear sustainability benefits to utilising one or more Green Belt locations, then this will form the basis of an argument that “exceptional circumstances” exist to justify releasing that land from the Green Belt.”
Catesby Estates supports this approach as it aligns with the requirements of the NPPF.

Other

ID sylw: 107944

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Rainier Developments support a Green Belt review. The Green Belt in South Warwickshire Topic Paper shows several of the best-connected settlements are within or surrounded by Green Belt. So are most train stations. Half the SGLs are within Green Belt. The Topic Paper is correct that Green Belt options should be considered to ensure development is suitably distributed and directed to the most sustainable locations and that a full Green Belt review is essential.

Exceptional circumstances as required by NPPF Paragraph 145 exist because of the significant number of homes required and limited capacity in existing settlements as evidenced by the Urban Capacity Study. NPPF Paragraph 146 states that exceptional circumstances include when authorities cannot meet their identified housing need through other means. The December 2024 NPPF introduced the concept of ‘grey belt’. Paragraph 148 states that where Green Belt land needs to be released, plans should give priority to previously developed land, then grey belt, then other Green Belt locations. The Council will need to follow this sequential approach when considering sites to release.

The Green Belt Review Stage 1 doesn't consider grey belt but concludes only 9 out of 113 parcels made a strong contribution to the Green Belt purposes. With over 100 parcels not strongly contributing towards these purposes, Rainier Developments would expect that a significant number of grey belt sites can suitably accommodate development. The next stage of the Review should draw clear conclusions on this. The Green Belt policy should make reference to Grey Belt and acknowledge that development in Green Belt can be appropriate if the Paragraph 155 criteria are satisfied. The ‘Golden Rules’ for residential development may also be referenced.

The draft Policy Direction suggests areas of land may be safeguarded to meet longer-term needs. This is supported, and would align with NPPF Paragraph 149(c). This could be for future needs of the South Warwickshire authorities, or those in the two Housing Market Areas they fall within. Further discussions and evidence-gathering is required to ascertain the level of unmet need in the HMAs. ‘Safeguarded land’ would be in addition to ‘reserve sites’ referenced in Policy Direction 4. These would meet the shorter-term needs of neighbouring authorities over the plan period, not beyond it.

Other

ID sylw: 107961

Derbyniwyd: 26/02/2025

Ymatebydd: Earlswood & Forshaw Heath Residents’ Association

The current Core Strategy has done nothing to protect the limited Green Belt that we have left and which is currently under such pressure to be developed. If you only have one objective, it should be to protect the last remaining areas of Green Belt in the District.

In the Ove Arup Ove Arup Green Belt Review, its second conclusion is that:
Regarding TiA Parish…

“The GB has only weak contribution towards preventing neighbouring settlements from merging.”

The logic behind this is that the parcels of land from a less essential gap between neighbouring towns, which is of sufficient scale that development is possible without any risk of merging. This isn’t evidence, this is purely opinion. Where’s the evidence?

Other

ID sylw: 108042

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Rainier Developments are supportive of a Green Belt review in to support the South Warwickshire Local Plan. Half of the Strategic Growth Locations are set within the Green Belt, where development would clearly align with the Councils’ selected spatial growth strategy, Sustainable Travel and Economy. The Topic Paper correctly recognises that all the options must be considered, including those in the Green Belt, to ensure that development is suitably distributed and directed to the most sustainable locations and a full Green Belt review is essential to developing a sound plan.
The definition of grey belt refers to previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in Paragraph 143 of the NPPF. Thus, with over 100 parcels not strongly contributing towards these purposes, Rainier Developments would expect there to be a significant number of grey belt sites within South Warwickshire that can suitably accommodate development, and the next stage of the Green Belt Review should draw clear conclusions on this. The Green Belt policy in the SWLP Part 1 will need to make reference to grey belt to ensure that it is consistent with the NPPF, as required by Paragraph 36.
Rainier’s land interests within Strategic Growth Area SG18 is within the Green Belt. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and identifying sites for development, where the most sustainable forms of development will require the inclusion of land around existing settlements, and to avoid isolated development which ‘jumps’ the Green Belt the Green Belt boundary review, and identification of land within the Green Belt for development is supported.
It is also considered that Rainier’s land interests could constitute grey belt land suitable for development in accordance with the tests for grey belt defined in the NPPF (December 2024).
The South Warwickshire Local Plan Green Belt Review Stage 1 document supporting the draft Plan has considered Rainier’s land interests at Birmingham Road within a wider parcel of land, STR6. In terms of purposes a, b and d of including land in the Green Belt the parcel as a whole is considered to make no contribution. The parcel/sites within it should then be considered further in terms of their potential to deliver development on grey belt sites.

Other

ID sylw: 108065

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Seven Homes support a Green Belt review. The Green Belt in South Warwickshire Topic Paper shows several of the best-connected settlements are within or surrounded by Green Belt. So are most train stations. Half the SGLs are within Green Belt. The Topic Paper is correct that Green Belt options should be considered to ensure development is suitably distributed and directed to the most sustainable locations and that a full Green Belt review is essential.

Exceptional circumstances as required by NPPF Paragraph 145 exist because of the significant number of homes required and limited capacity in existing settlements as evidenced by the Urban Capacity Study. Paragraph 146 states that exceptional circumstances include when authorities cannot meet identified housing needs through other means. The December 2024 NPPF introduced ‘grey belt’. Paragraph 148 states that where Green Belt land needs to be released, plans should give priority to previously developed land, then grey belt, then other Green Belt locations. The Council will need to follow this sequential approach when considering sites release.

The Green Belt Review Stage 1 doesn't consider grey belt but concludes only 9 out of 113 parcels made a strong contribution to the Green Belt purposes. With over 100 parcels not strongly contributing, Seven Homes would expect a significant number of grey belt sites can suitably accommodate development. The next stage of the Review should draw clear conclusions. The Green Belt policy should make reference to Grey Belt and acknowledge that development in Green Belt can be appropriate if the Paragraph 155 criteria are satisfied. The ‘Golden Rules’ for residential development may also be referenced.

The draft Policy Direction suggests areas of land may be safeguarded to meet longer-term needs. This is supported, and would align with NPPF Paragraph 149(c). This could be for future needs of the South Warwickshire authorities, or those in the two Housing Market Areas they fall within. Further discussions and evidence-gathering is required to ascertain the level of unmet need in the HMAs. ‘Safeguarded land’ would be in addition to ‘reserve sites’ referenced in Policy Direction 4. These would meet the shorter-term needs of neighbouring authorities over the plan period, not beyond it.

Land at Russells Garden Centre, Mill Lane, Baginton is within parcel BAG2 assessed in the South Warwickshire Green Belt Review Stage 1. The Site is in the far north western corner of the parcel. The wider parcel is quite large and generally rural and open. Overall, the parcel is considered to play no contribution to checking the unrestricted sprawl of large built-up urban areas (purpose a), a weak contribution to prevent towns from merging (purpose b), and no contribution to preserving the setting and special character of historic town (purpose d).

Development of the site would include a large area of previously developed land and whilst the remainder of the site is not PDL it is horticultural in character with numerous structures, including greenhouses and polytunnels. The floodplain to the south of the site limits the extent of development across the wider site. Whilst the Site is a short distance from the edges of Coventry the existing Kenilworth Bypass creates a physical barrier between the two settlements. Whilst not discussed within the latest Green Belt Review, the Joint West Midlands Green Belt Study 2015 did discuss long-range intervisibility with the historic core of Coventry from areas of high ground to the south. Given the site’s location in the far northwest corner of the Green Belt parcel and its PDL character, development is not considered to undermine purpose (d). In addition, the Site is beyond the boundaries of the Baginton Conservation Area.

Other

ID sylw: 108112

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

It is in our view imperative that the SWLP deals head on with the fact that the release of existing Green Belt land will be required to meet development needs over the Plan period. Such a case is not made clearly at section 4.9, and we strongly recommend that this is remedied in the forthcoming Regulation 19 Consultation draft of the Plan.
We support the recognition at Section 4.9 that “Some of South Warwickshire’s most sustainable locations fall within the Green Belt. For example, all of our train stations are either in or close to the Green Belt. This means that in order to deliver a truly sustainable pattern of growth, the SWLP needs to consider all options, including Green Belt options”. This was a point made in our previous representations and reflects the direction of travel contained within Government rhetoric regarding Green Belt land.
Chapter 13 of the NPPF refers to ‘Protecting Green Belt land’, with paragraph 146 clearly setting out that an authority’s inability to meet its identified need for homes would be considered to constitute ‘exceptional circumstances’ justifying the alteration of Green Belt boundaries. We recommend that due regard is given to national policy in the drafting of the SWLP, given the relevance of this particular element of the NPPF to the situation in South Warwickshire.
Paragraph 148 of the NPPF goes on to set out that where it is necessary to release Green Belt land for development, “plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations”. As previously set out and accepted by the Councils in their evidence base and emerging SWLP, there is insufficient previously developed land to meet development needs. Attention must therefore turn to greenfield and inevitably to land currently located within the Green Belt where this offers the most sustainable opportunities for development.

Yes

ID sylw: 108118

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Catesby Estates are supportive of a Green Belt review to support the South Warwickshire Local Plan.
Much of South Warwickshire is within the Green Belt, and without Green Belt sites, Stratford and Warwick would be unlikely to meet their housing need; Paragraph 146 of the NPPF states that exceptional circumstances can include instances where an authority cannot meet its identified need for homes through other means, on land outside of the Green Belt.
The December 2024 NPPF introduced significant changes to national Green Belt policy.
The Green Belt policy in the SWLP Part 1 will need to make reference to grey belt to ensure that it is consistent with the NPPF, as required by Paragraph 36. This is also recommended by the SA, at paragraph 3.7.6 in Appendix E.
The draft Policy Direction suggests that areas of land may also be safeguarded to meet longer-term needs. This is supported, and would align with Paragraph 149(c) of the NPPF, which encourages this where necessary. Such land may be set aside to meet the future needs of the South Warwickshire authorities, or those in the two Housing Market Areas they fall within, with new Green Belt boundaries created which endure in the long term as required by Paragraph 145 of the NPPF; as highlighted elsewhere in these representations, further discussions and evidence-gathering is required in order to ascertain the level of unmet need which may need to be accommodated on such sites. It must be emphasised that ‘safeguarded land’ would need to be in addition to the ‘reserve sites’ referenced in Policy Direction 4, which would be meeting the shorter-term neighbouring authorities over the plan period, not beyond it.
Catesby land interests within Strategic Grown Area SG04 are all within the Green Belt. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and identifying sites for development, where the most sustainable forms of development will require the inclusion of land around existing settlements. It would be somewhat nonsensical to not undertake a Green Belt boundary review as this would result in isolated development beyond the extent of the Green Belt, which cannot be a sustainable strategy. A Green Belt boundary review and identification of land within the Green Belt for development is therefore supported. 4.38. It is also considered that Catesby Estates’ land interests could constitute grey belt land that could be suitable for development in accordance with the tests for grey belt defined in the NPPF (December 2024). The South Warwickshire Local Plan Green Belt Review Stage 1 document supporting the draft Plan has considered Catesby land interests as specific sites KEN8 and KEN9. In terms of purposes a, b and d of including land in the Green Belt both areas made at best a weak contribution to purpose b (KEN9). The parcels should then be considered further in terms of their potential to deliver development on grey belt sites. This is discussed further in Section 11.

Yes

ID sylw: 108167

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

Policy Direction 7 – Green Belt
Although Bellway’s site at Bordon Hill is outside of the Green Belt, we support the Councils approach to undertaking a Green Belt review as an integral part of the evidence base underpinning the SWLP.
We attended the workshop run by the two Councils during which focussed working groups were formed to discuss how the SWLP housing requirements (at that time based upon the HEDNA and not reflective of the now far higher Standard Method) could be sustainably distributed across the plan area. It was clear that with a ‘policy off’ approach the distribution of housing was

challenging, in a ‘policy on’ scenario excluding the Green Belt it was not possible to deliver a sustainable development strategy. Applying the Standard Method makes the position more acute still.
It is clear therefore that Green Belt release is an essential component to the SWLP, and as a result undertaking a Green Belt Review is vital if the SWLP is to be found sound – put simply, the plan cannot proceed without Green Belt release.

Other

ID sylw: 108191

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips support the SWLP identifying potential SGLs within the Green Belt. It is possible for Green Belt land to be the most sustainable location for development even where other sources of greenfield land is potentially available. This accords with the sequential test in NPPF Paragraph 147 as it is clear there is insufficient capacity to deliver purely through brownfield land and optimising densities, and other authorities in the Housing Market Area are equally constrained by Green Belt and/or tight administrative boundaries.

Land at Stratford Road, Hockley Heath was found to make only a moderate contribution to Green Belt in the Stage 1 Review. St Philips believe the site constitutes 'Grey Belt' as it does not strongly contribute to purposes a, b or d and there are no Footnote 7 constraints on the site. Additionally it is well-located to access a range of key local amenities in Hockley Heath and Solihull. The site lies on one of the main bus corridors providing access to larger settlements and is approximately 2km from Dorridge Station. Hockley Heath is a sustainable location for growth within South Warwickshire and growth would promote sustainable patterns of development in accordance with the NPPF.

Yes

ID sylw: 108209

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Persimmon are supportive of a Green Belt review in to support the South Warwickshire Local Plan. Exceptional circumstances would exist here, due to the significant number of homes which need to be provided, in the context of there being limited capacity within settlements to deliver new housing

The South Warwickshire Green Belt Review Stage 1 (October 2024) does not consider grey belt. However, it does conclude that only 9 out of 113 Green Belt parcels were assessed as making a strong contribution to the Green Belt purposes.

The definition of grey belt refers to previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in Paragraph 143 of the NPPF. Thus, with over 100 parcels not strongly contributing towards these purposes, Persimmon would expect there to be a significant number of grey belt sites within South Warwickshire that can suitably accommodate development.

The Green Belt policy in the SWLP Part 1 will need to make reference to grey belt to ensure that it is consistent with the NPPF, as required by Paragraph 36.

The draft Policy Direction suggests that areas of land may also be safeguarded to meet longer-term needs. This is supported, and would align with Paragraph 149(c) of the NPPF, which encourages this where necessary.

Other

ID sylw: 108341

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Caddick Land supports this approach as it aligns with the requirements of the NPPF. However, it is worth emphasising that the above paragraph, in conjunction with the Green Belt Review Stage 1 (September 2024), make clear the Stage 1 Review considers only broad parcels and areas of Green Belt and that there will be a need to undertake more detailed site-specific Green Belt assessment work as the SWLP progresses.

The Stage 1 Review methodology clarifies that this site-specific assessment will form part of a Green Belt Review Stage 2 which will consider the status of washed over villages within the Green Belt and assess these against paragraph 149 of the NPPF.

Caddick Land reserves the right to comment on the Stage 2 Review at the appropriate time and further comment is made in respect of the Stage 1 Review in Chapter 8 of this Representation in the context of the HELAA findings regarding Land to the North and South of Hill Wootton
Road.

Yes

ID sylw: 108353

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We are supportive of the sequential approach that the Council pursue under Draft Policy Direction 7 when allocating strategic areas of growth.

Given the limited development capacity on potential brownfield sites as the Council’s Brownfield Land Registers show, we strongly urge the Council to prioritise the allocation of potential strategic growth locations, in particular those on non-Green Belt areas, including this Site, to minimise the extent of Green Belt land to be released while accommodating South Warwickshire’s housing needs.

With the Site’s sustainable location to an existing upper tier settlement, we consider that the Welsh Road West land to be the most suitable and deliverable option to provide sustainable levels of growth, deliver homes that meet the needs of all communities including existing residents, support the growth in employment opportunities in Southam, and contribute towards reducing carbon emissions through minimising distance of travel. These benefits arising from the allocation of the Site should be prioritised and duly considered prior to any release of other Green Belt land.

Yes

ID sylw: 108368

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

8.1 Mackenzie Miller Homes is supportive of protecting the Green Belt and generally supports
the Draft Policy Direction 7 – Green Belt. It should be noted that Mackenzie Miller Homes’
Site is not within the designated Green Belt.
8.2 While Green Belt land can offer a more sustainable location for development to promote
sustainable patterns, even when other greenfield land is available, the SWCs should also
consider sustainably located greenfield land, especially if it aligns with the proposed Spatial
Growth Strategy.
8.3 Mackenzie Miller Homes acknowledges that the SWLP may need to release Green Belt land
due to the significant housing needs of the SWCs under the new SM. It is apparent that
exceptional circumstances can be demonstrated, and Green Belt release should be
considered alongside brownfield and greenfield land. Nonetheless, the NPPF outlines a
'sequential approach' in Paragraph 147a,
“Before concluding that exceptional circumstances exist to justify changes to Green Belt
boundaries, the strategic policy-making authority should be able to demonstrate that it
has examined fully all other reasonable options for meeting its identified need for
development. This will be assessed through the examination of its strategic policies, which
will take into account the preceding paragraph and whether the strategy:
a makes as much use as possible of suitable brownfield sites and underutilised
land”
8.4 Therefore, Mackenzie Miller Homes strongly believes that the SWLP should direct growth
to Shipston and allocate Mackenzie Miller Homes’ Site in the SWLP, following the
'sequential approach' before releasing Green Belt land as per the relevant sections of the
NPPF.

Yes

ID sylw: 108427

Derbyniwyd: 04/03/2025

Ymatebydd: Landowner Site A1

Asiant : Morgan Elliot Planning

This policy is supported.

Yes

ID sylw: 108460

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group agree that the SWLP will apply national planning policy to proposals within the Green Belt.
It is agreed that the SWLP will take a sequential approach to allocating strategic areas of growth and new settlements.
It is agreed that the SWLP will also consider whether the Spatial Growth Strategy's patterns of development result in a justification for any new Green Belt.
The land so identified relates well to the existing settlement pattern and is relatively close to the Stratford-upon-Avon Park and ride. A compact extension to the urban form of Stratford -Upon-Avon would be created.

Other

ID sylw: 108481

Derbyniwyd: 06/03/2025

Ymatebydd: Emma Guest

* Living in the Green Belt is a joy and I feel that any development of it cannot be right and will have a major impact on woodland and the surrounding countryside.

* This in turn will affect how the area looks.

Other

ID sylw: 108493

Derbyniwyd: 03/03/2025

Ymatebydd: Sally Rees

Destruction of Green Belt and Countryside (Chapter 5)
• The Plan proposes the large-scale removal of protected Green Belt land, which contradicts NPPF Paragraph 138, requiring exceptional circumstances for Green Belt release.
• South Warwickshire’s countryside, farmland, and natural landscapes are at risk of permanent loss, damaging the area’s heritage and environmental sustainability.
• The Plan does not adequately consider the cumulative impact of Green Belt erosion on biodiversity, flood risk, and climate resilience.
Conclusion: The Local Plan must prioritize land conservation and reinstate Green Belt protections.

Yes

ID sylw: 108509

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

In principle, the proposed sequential approach to allocating strategic growth locations and any new settlement within the SWLP is supported. A sequential approach is consistent with national planning policy which makes clear that the Green Belt should not be a barrier to development per se – so long as the land in question is edge of settlement, or in an otherwise sustainable location; provides suitable affordable housing and local infrastructure (in accordance with the new ‘Golden Rules’); is not subject to an existing environmental designation; and does not serve – or significantly undermine – purposes (a), (b) and (d) of the Green Belt.
4.30 The Bird Group do, however, wish to restate our view that if the SWLP is to be taken forward in two parts, some smaller sites should be allocated for development in Part 1 to help ensure the Councils can maintain a 5-year housing land supply. Consequently the proposed assessment of non-Green Belt locations to accommodate South Warwickshire's housing (and employment land needs) should not, for Part 1, be confined to strategic areas of growth and potential new settlement locations but should also be used to help identify those non-Green Belt sites which are well located.