No

ID sylw: 105312

Derbyniwyd: 28/02/2025

Ymatebydd: Warwickshire Wildlife Trust

Warwickshire Wildlife Trust is concerned by the scale of the proposed housing. The Plan reports a need for 1,679 dwellings per annum, but suggests allocating 600 surplus houses to allow sufficient flexibility. This will have a significant negative impact on the important habitats and protected species across the area. Houses must be delivered in suitable numbers but in suitable locations and must not disregard the Environment Act 2021 target of 30% of land allocated to nature and in recovery by 2030.

Many housing sites are in Green Belt, an important designation which protects the edges of wildlife sites and provides a transitional and safe area for protected and declining species. WWT is not satisfied that the Councils have carried out a detailed Green Belt Review, particularly Stage 2 work and landscape impact assessments. They have not done individual Flood Assessment work (SFRA part 2s) in order to properly select sites.

No

ID sylw: 105313

Derbyniwyd: 28/02/2025

Ymatebydd: Warwickshire Wildlife Trust

We have reviewed a list of key Local Wildlife Sites that would be affected. The Council should refer to the most current Local Wildlife Site layer.

SG01 and SG02 - Broadwells Wood and Black Waste Wood Local Wildlife Site (LWS) and Wainbody and Kenilworth Road Woods LWS, Kenilworth Common LWS and River Sowe & Finham Brook & lakes
SG03 - Stonebridge Meadows LWS and River Sowe Potential local Wildlife Site
SG05 - River Avon LWS and Hill Wootton Farm Meadows Potential local Wildlife Site, North and South Cubbington Woods LWS, Waverley and Weston Wood LWS
SG12 - Long Itchinghton Quarry LWS and River Itchen PLWS
SG13 - Lighthorne Quarry LWS and Chesterton Wood LWS
SG14 - Oakham Coppice LWS, River Avon LWS, Itchington Holt and the Centenary Way
SG15/16 - River Avon and tributaries LWS and Hampton Wood LWS, Grove Fields Lane LWS, Wasperton Manor Farm LWS, Hampton Lucy Escarpment LWS, Charlescote gravel pits and Thelsford brook LWS
SG10/11 - River Avon and tributaries LWS
SG10/X1 - Oakley Wood
SG17 Shipston upon Stour - River Stour PLWS
SG20 - River Avon and tributaries LWS
SG18 - Hatton Hill Fields PLWS, Brownley Green Lane LWS, Home Farn Woods PLWS, Hatton Park LWS and Grand Union Canal West LWS
SG19 - River Avon LWS and disused railway PLWS and Bridgetown Fields LWS
SG20 - River Avon LWS
SG21 - River arrow LWS and Coldcomfort Wood PLWS
SG24 - Stratford-Upon-Avon Canal
SG07 - River Avon LWS and Budbrooke Farm woodlands LWS and Warwick Cemetery LWS
SG22 - New Coppice LWS, Coughton Park LWS Studley
SG23 - Mockley wood LWS, River Alne, Mockley Manor Farm PLWS

No

ID sylw: 105314

Derbyniwyd: 28/02/2025

Ymatebydd: Warwickshire Wildlife Trust

Warwickshire Wildlife Trust is concerned about potential environmental impacts of new settlements allocations. Important sites, including LWSs and SSSIs, have been overlooked in the selection process. Proposals within the Green Belt threaten designated sites and protected species, reducing access to nature for urban residents.

Impacted designations include the following:
A1/2- River Alne LWS, Round Wood and Long Wood LWS, Grove Wood PLWS and Grotton Hill Wood LWS
C1 - Gilbert’s and Claypits coppices, Linnear Woodland LWS
E1 Allocation - adjoining AONB, Meon Vale LWS, River Avon LWS and the greenway, dismantled railway, Welford Hill Farm Meadows PLWS, Rumerhill Coppice PLWS and Coxmere Coppice PLWS
BW - Newfoundland Wood LWS, Stratford Canal PLWS, River Avon LWS and Wood by Churchill
G1 - Itchington Holt PLWS
F1 - Long Itchington and Ufton woods SSSI
F2 - Deppers Bridge Meadow PLWS
F3 - South Southam LWS and Disused railway LWS.

No

ID sylw: 105315

Derbyniwyd: 28/02/2025

Ymatebydd: Warwickshire Wildlife Trust

Evidence recommends that between 75 and 125ha of land be allocated for Employment Growth, however the Plan proposes 125ha, the upper limit of development. This is unnecessary and will have larger impacts on important environmental assets and habitats in the area, as well as designated sites and protected species, and does not align with the Government’s 30% by 2030 targets.
Warwickshire Wildlife Trust is also concerned regarding the lack of up to date employment need data, and no evidence for Strategic Industrial Need before 2045.
The allocations are directly next to Chesterton Wood, an important Local Wildlife site, and extremely close to the River Avon and Tributaries LWS, Redlands Brake PLWS, New Waters LWS, Budbrooke Farm Woodlands and Black Brake Plantation LWS, development on which would have detrimental effects for wildlife and climate change targets.

Other

ID sylw: 107383

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

Warwickshire Wildlife Trust are extremely concerned regarding the Preferred Options Local Plan for South Warwickshire.
Particularly the housing allocations and largescale new settlements that are on and close to important ‘Local Wildlife Site’, SSSIs, Nature reserves, Ancient Woodlands and in the Greenbelt. We are concerned regarding the loss of threatened habitats and the impact increased traffic/lighting/noise and activity in these areas, would have on legally protected species and important wildlife habitats.


The Local Plan includes new settlements and land for large-scale housing and employment next to and on important Local Wildlife Sites, and in a large number of cases on existing Green Belt land. These areas act as vital refuges for wildlife in a landscape which is already fragmented by roads, housing, and development.
The housing targets set out in the plan, importantly seem to have been grossly exaggerated over and above the needs assessment. Putting additional pressure on important legally protected species and wildlife sites.

Other

ID sylw: 107384

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

We are also very disappointed about the removal of the Wildbelt Policy.
11.1 states 80% of respondents supported the inclusion of a Wildbelt Policy to designate land specifically for nature recovery.
The plan removes the policy, contrary to previous consultation results.
Local Nature Recovery Strategies (LNRS) are also different from Wildbelt and Wildbelt would actually be for “safeguarding” sites in recovery. LNRS is not a designation, so it is unclear how LNRS alone would safeguard areas for nature. How will the Councils achieve the Environment Acts 30% of land in nature recovery by 2030 and solve the biodiversity and climate emergencies, without allocating actual land for protection and enhancement

The plan also hasn’t produced a detailed Green/Blue infrastructure evidence base that ambitiously allocates land for enhancement , before the housing allocations were made, and doesn’t include a detailed strategic policy looking at opportunities for wider corridors.

No

ID sylw: 107385

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

No. WWT believe that the policy doesn’t provide enough detail on how important environmental assets will be protected and ‘enhanced’, especially when a large number of the allocations are next to and even covering important designated Local Wildlife Sites.
Under the NERC duty and Wildlife and Countryside Act Councils have a duty to protect biodiversity. The 30 by 2030 target is also now in the Environment Act therefore the Councils will need to be more ambitious in terms of enhancements to reach this.

No

ID sylw: 107386

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

No. support the inclusion of such a policy however the policy says ‘expected to support the principles’ and this wording isn’t strong enough. If the Councils intends to reach 30% of land dedicated to nature and in recovery by 2030, as stated in the Environment Act 2021, then more ambitious targets are needed.
The Local Nature Recovery Strategy is at a too early stage to be solely relied upon. The Councils needs a robust evidence base early on to influence strategy decisions and allocations.

No

ID sylw: 107388

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

No. Warwickshire Wildlife Trust is not satisfied with the councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain.
Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater targetshould be delivered. A number of other Councils have already got plans through Examination with 20%.
If the Councils are serious about meeting the Governments 30 by 2030 targets in the Environment Act and Climate and Biodiversity Emergencies the plan needs to be ambitious.

No

ID sylw: 107389

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

No. It is unclear how this will deliver wider connecting corridors which are more substantial than the proposed small scale on-site improvements. The councils should update their Green/Blue Infrastructure evidence base to include ambitious new areas shown on the map, in line with the NPPF and in time to influence chosen housing strategies and chosen sites in the Local Plan.
It is not enough to rely on general GI strategies that don’t set out ambitious new areas.