Given that 81% of the District is Green Belt and is likely to be the most controversial part of the plan, we would have expected the Green Belt and Green infrastructure sections to be given a more prominent position earlier in the document, rather than on pages 87 and following. Selective grouping of certain chapters could also help to provide more synergy. For example, these chapters are more closely related and could naturally follow on:

* Green Belt
* Green Infrastructure
* Built Environment
* Historic Environment.
* Climate Change
* Flooding & Water

* Housing
* Economy
* Retailing & Town Centres
* Culture & Tourism

The approach taken by Warwick District Council towards the review of Green Belt boundaries to accommodate development within the plan period accords with the previous PPG2 'Green Belts' and the NPPF. The NPPF states that "Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of a Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term so that they should be capable of enduring beyond the plan period."

The Plan acknowledges that the preferred option for housing (approximately 600 dwellings pa) will need to be met largely on strategic greenfield sites on the edge of the built-up areas (which will be predominantly existing Green Belt) and within/or on the edge of some villages to allow for a hierarchy of growth in the rural area.

The National Trust has some concern about removing villages from the Green Belt and then drawing entirely new Green Belt boundaries around the settlements to allow for development, rather than simply amending the existing boundary to accommodate urban/village extensions, which would be less disruptive. Redrawing boundaries may increase pressures from developers to also accommodate 'Safeguarded Land' in addition to extensions. There is also a danger that if villages are removed from the Green Belt, they may not be re-designated and would then need to be protected by other development management policies, as referenced in NPPF Para 86.

The Trust would wish to be involved in any discussions about the designation of new boundaries in the vicinity of its properties.

Policy PO16 may not provide sufficient flexibility for the National Trust to accommodate limited extensions to our properties in the Green Belt that do not conflict with the main purposes of the Green Belt and its openness, in accordance with the NPPF. For example, the NPPF allows for limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development. It also allows for the re-use of buildings, provided that the buildings are of permanent and substantial construction, and the provision of appropriate facilities for outdoor recreation, which could apply to many Trust properties (Para 89).

The National Trust welcomes the reference to the "Council supporting the preparation of the emerging Coventry, Solihull and Warwickshire Green Infrastructure Strategy. This will ensure that biodiversity is planned at a landscape scale, enhancing linkages and restoring fragmented habitats, access to large scale natural green spaces and improvements to landscape character." The reference in the policy should, however, be: Warwickshire, Coventry & Solihull (not Coventry, Solihull & Warwickshire).

The Warwickshire Landscapes Guidelines originally identified Enhancement Zones considered to be strategic priorities for landscape conservation and enhancement. In the light of new information, including the regional character area mapping of the Midlands, the Habitat Biodiversity Audit (HBA) and Connectivity/Opportunity Mapping, the emerging GI Strategy may be recommending that these Enhancement Zones be re-assessed in order to identify key priorities for conservation and enhancement. In particular:

1. areas in which the primary aim should be landscape conservation;
2. areas in which the primary aim should be landscape enhancement; and
3. areas in which the aim should be a roughly equal prescription of landscape conservation and enhancement.

An integrated and partnership approach will be required and the National Trust would like to be involved in this process. This will be particularly important in relation to planning for sustainable landscapes in and around the urban fringe, major growth areas and transport infrastructure projects, including HS2.

There is compelling evidence that when landscape is placed at the heart of the development process, developers can profit, while businesses and communities reap the environmental, social and economic benefits. In particular, planning and implementing substantial landscape frameworks, well in advance of major developments and transport infrastructure, can bring many benefits, including safeguarding and enhancing vital landscape assets, helping to create a sense of place for new development and retaining vital links with the past. This need to consider landscape planning well in advance of development, should be emphasised in the GI section of the Plan.

There is no reference in the document to minimising the impact of light pollution on local amenity and intrinsically dark landscapes, in accordance with NPPF. The NPPF also for the first time allows local authorities to identify and protect Areas of Tranquillity (Para 123), which have remained relatively undisturbed by noise and are prized for their recreational and amenity value.

In view of the importance of Culture and Tourism to the local and sub-regional economy, the National Trust has particular reservations about the following wording, which together with Green Belt policy, could potentially restrict some aspects of the Trust's work in the future. There would certainly be some debate about the definition of "significantly intensify" and uncertainty over whether policies referring to visitor accommodation are also intended to apply to visitor attractions and visitor facilities. For example, how would this apply to 364 day opening of Trust properties in the future?

"Extensions to visitor accommodation in the rural area will only be permitted where these do not significantly intensify the used of the site or establish new uses which are not ancillary to the normal business of the visitor accommodation."