Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S7.2 For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF “exceptional circumstances” principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. I do not feel the plan should allow for more small-scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt.The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

QS4.1 Growth of existing settlements: My view is that growth of existing settlements should only be considered where it does not require development in the greenbelt. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are suggested in the current consultation document. There are ample non-greenbelt options for new settlements. Q-S7.2 For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF “exceptional circumstances” principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. I do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. In addition, the site proposed includes an area prone to flooding, completely lacks sufficient road infrastructure to support an increase in traffic, provides a livelihood for two tenant farmers and is of inestimable value to the health and mental well-being of many local people. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. Why do something to make it worse? There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Issue S6: A review of Green Belt boundaries: The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives.

Q-S2: Option S2b: Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes Chapter 11 of the NPPF encourages effective use of land, including: taking into consideration the need for different types of housing; the desirability of maintaining an area’s prevailing character and setting; and the use of minimum density standards for city and town centres and other locations that are well served by public transport. There is role for the intensification of development in certain areas of the SWLP area as part of the wider strategy. However development site character and context will vary significantly across the SWLP area, both within town centres and outside of the town centres. Planning policies will need to be sufficiently flexible to be able to accommodate this. Accordingly option S2b will enable a well-planned best use of available land, incorporating intensification where appropriate but without prejudicing the need to reflect context and character on a site-by-site basis, particularly on the rural fringes of settlements. The PPG1 cautions that measuring ‘dwellings per hectare’ can: “encourage particular building forms over others, in ways that may not fully address the range of local housing needs… It is therefore important to consider how housing needs, local character and appropriate building forms relate to the density measures being used.” Therefore it is important that future policy wording should allow for density and the approach to intensification to be determined on a site by site basis. 1 Planning Practice Guidance: Paragraph: 005 Reference ID: 66-005-20190722.

Q-S3.2: Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Paragraph 119 of the NPPF is clear that planning policies should make effective use of land, including as much use as possible of previously-developed or “brownfield” land. Furthermore, NPPF paragraph 120 states that planning policies should give substantial weight to the value of using suitable brownfield land. Nevertheless this should be viewed in the context of NPPF paragraph 73, which identifies that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as extensions to existing villages and towns, provided that they are well located. Although significant encouragement is given to the development of brownfield land, it is still necessary to provide an adequate justification for the use of brownfield land in accordance with the strategy for the sustainable distribution of growth within the Local Plan area. It should not the case that brownfield land should be considered over all other options if the specific sites are not suitable, viable, deliverable or sustainable locations for housing in line with the Councils’ strategy. To ensure a plan led approach, the Councils’ strategy should be to follow a clear locational strategy that promotes sustainable development, which includes the optimisation of brownfield land where appropriate, whilst also acknowledging the role that greenfield land should play. This approach is consistent with option S3.2a.

Q-S4.1 Yes As included in response to QS3.2, NPPF paragraph 73 identifies that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as extensions to existing villages and towns, provided that they are well located. The growth of existing settlements can take account of the existing services, facilities and infrastructure that are already in place to support sustainable growth.

Q-S5.2 Do you think new settlements should be part of the overall strategy? Possibly The delivery of new settlements could be taken into consideration as part of the wider strategy, given the potential that they could offer to make a significant contribution to new housing delivery. It should however be recognised that the delivery from large strategic sites can be very slow in the early stages of the new Local Plan period. As set out in the Lichfields ‘Start to Finish Report’ (Feb 2020) the average time from the validation of first application to completion of the first dwelling for a scheme of 2,000+ dwellings is 8.4 years. As such it is crucial that a sufficient number of non-new settlement sites are allocated to address the first 0-10 years of the plan period. This should include a mix of substantial strategic sites and smaller sites.

Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? Yes (an approach which capitalises on opportunities in proximity to existing rail corridors should be carried forward into the final chosen strategy). This approach should be taken into account in relation to the location of new development in general, especially more substantial strategic sites, and not just limited to new settlements. South Warwickshire has some unique opportunities for locating new development close to public transport corridors, especially including rail corridors. The South Warwickshire authorities benefit from a number of railway stations which provide links to a multitude of locations across both HMAs and the wider region. Development in close proximity to these stations will improve the utilisation of these stations and potentially provide a critical mass to assist with sustaining the facilities at these stations and their viability. Further commentary in relation to this is set out in response to Q- 7.2 below.

Whilst the question is not posed under Issue S6 (Green Belt), there is a need to undertake a review of the Green Belt in order to inform the consideration of where the most suitable and sustainable sites are located and, if within the Green Belt, which areas of Green Belt can be released without significantly impairing the functions of the Green Belt within South Warwickshire. The planning system must make land available in the right places and for the right forms of development. The undertaking of a Green Belt Review is an essential part of the process of making developable land available in the most sustainable locations. NPPF paragraph 142 highlights that when drawing up or reviewing Green Belt boundaries the need to promote sustainable patterns of development should be taken into account. In establishing the housing requirements for an area, particularly if affordability concerns are to be addressed at larger settlements surrounded by Green Belt, Green Belt cannot currently be used as: the sole justification to direct development elsewhere; or as the sole justification to artificially suppress housing delivery; or the rationale for distributing housing to less sustainable locations. The 300,000 homes a year target set by the Government, and the subsequent response to the consultation on housing numbers in December 2020, identifies Coventry and Birmingham as being two key areas for housing growth to meet the target. South Warwickshire is adjacent to the Coventry City Council administrative area. Whilst the evidence base to underpin the new Coventry Local Plan is not yet available it is expected that Coventry City Council will be unable to meet its housing needs in full and a contribution to this unmet need should be a key part of the strategy for the SWLP from the start of the Local Plan-making process. BDWH has undertaken a review of environmental and technical considerations relating to the residential development opportunity that it is promoting to the north west of Warwick Parkway Railway Station. It is concluded that the proposed quantum of development can be accommodated within the existing landscape context, bolstered by additional landscape planting, to avoid significant harm arising. This is set out further in a Vision Document that is being submitted in support of these representations.

Q-S3.2 Please select the option which is most appropriate for South Warwickshire. Option S3.2c: None of these 2.6 St Philips considers that the SWAs priority should be to direct development to the most sustainable locations. St Philips recognises that the NPPF places emphasis on the need to make as much use of brownfield land as possible, with paragraph 119 stating that: “Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.” 2.7 Paragraph 120 of the NPPF continues by stating that “Planning policies and decisions should: • give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land; and • promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively.” 2.8 However, it should be noted that whilst the use of brownfield sites is emphasised, there is a need to consider the NPPF as a whole. Paragraph 11a of the NPPF is clear that “all plans should promote a sustainable pattern of development”. In this regard, whilst suitable brownfield sites will often naturally emerge as sustainable locations for development, it is possible for greenfield land to provide a more sustainable location for development than unsuitable brownfield land. 2.9 St Philips also notes that the SWLP ‘Urban Capacity Study (October 2022)’ has established that South Warwickshire is unlikely to be able to meet its development needs solely through the use of previously developed land1.Therefore, regardless of the approach taken by the SWLP, there will still be a need to identify significant amounts of suitable greenfield land for development. In this context, St Philips believes the Councils approach should emphasise sustainability, rather than arbitrarily prioritising brownfield sites over more sustainable greenfield locations. St Philips would therefore support the effective reuse of brownfield land alongside the release of greenfield land in sustainable locations as directed by the Settlement Hierarchy or through the delivery of a new settlement (subject to consideration of the delivery of core facilities and accessibility). Q-S5.2 Do you think new settlements should be part of the overall strategy? Yes. As stated, the NPPF is clear that the supply of large numbers of new homes can often be best achieved through planning for larger-scale developments (Para 73). Importantly, it is also clear that plans should be prepared positively, in a way that is aspirational but deliverable (Para 16b), and should identify specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan (Para 68b). However, for a plan to be found ‘sound’, it must set out an appropriate strategy, taking account of reasonable alternatives, and be based on proportionate evidence (Para 35b). In this regard, it is also important to note that the NPPF shifts the need to consider viability to the plan-making stage, requiring authorities to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability (Para 68). The Planning Practice Guidance [PPG] provides further clarity for new settlements, stating that LPAs should demonstrate that there is a reasonable prospect that large scale developments can come forward. In particular, this should include a realistic assessment about the prospect of sites being developed and should engage with infrastructure providers to ensure that the infrastructure requirements are not beyond what could reasonably be considered to be achievable within the planned timescales. St Philips therefore does not consider that new settlements are the panacea for housing delivery. Whilst the proposed SWLP plan period would extend up to 2050, and conceivably enable sufficient time for a new settlement to fully deliver, there are still legitimate issues regarding this type of housing delivery and the evidence required to successfully underpin a proposed allocation – notwithstanding that SOADC secured the allocation of Long Marston Airfield. In this regard, St Philips welcomes the IOs recognition that whilst new settlements can be an effective way of delivering housing growth, further detailed assessment of the identified potential new settlement locations is required. The IO rightly acknowledges that “there is the possibility once these detailed assessments have taken place and in light of any comments received to the Issues and Options consultation, none of the potential locations are deemed suitable” (IO, page 49). It is particularly important that, where new settlements are intended to be a large proportion of areas housing needs, there should be a robust – and proportionate – evidence base demonstrating that the site is deliverable. In the absence of this, there is a very real risk that a Local Plan could be found ‘unsound’ at examination. Indeed, the examination of the North Essex Authorities’ [NEA] Section 1 Local Plan highlights the above issues. In particular, to meet housing needs over the 2013-2033 plan period, it proposed the allocation of three garden communities. However, the Inspector concluded that two of these proposed settlements should be deleted in order for the plan to proceed as they weren’t deliverable, on viability and infrastructure grounds. Furthermore, at the examination of Hart District Council’s ‘Hart Local Plan (Strategy and Sites) 2032’, the Inspector’s concern was that the new settlement was being advanced as a long-term solution, but no alternatives to that option had been considered or properly tested in preparing the plan. The Inspector also noted that “there is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership” [IR63]. In any event, the NPPF is clear that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed” (Para 60). As discussed, the NPPF emphasizes the importance of small-medium sites, stating that small and medium-sized sites can make an important contribution to meeting the housing requirement of an area, and are built out relatively quickly (Para 69). In this context, notwithstanding St Philips position on issues associated with pursuing New Settlements, the SWLP will need to allocate a variety of small-medium sized sites to deliver housing in the first 5-15 years of the plan period. Q-S7.2 For each growth option, please indicate whetheryou feel it is an appropriate strategy for South Warwickshire: The IO sets out five spatial Growth Options, comprising: a Option 1: Rail Corridors b Option 2: Sustainable Travel c Option 3: Economy d Option 4: Sustainable Travel and Economy e Option 5: Dispersed For each growth option an indicative list of settlements is provided. In this regard, St Philips is promoting land for residential development on the edge of Stockton, which is identified as a Category 2 Local Service Village within the Core Strategy. In the context of St Philip’s site, it is welcome that Stockton is identified as a potential location within Growth Option 5 (Dispersed). However, St Philips considers that Stockton should also be featured in Growth Option 2 (Sustainable Travel) and Growth Option 4 (Sustainable Travel and Economy). In regard to sustainable travel, Stockton is well connected to existing bus networks, with services 63 and 64 connecting the village to Leamington-Spa and Rugby respectively. St Philips also considers that growth at Stockton would contribute to the vitality of the settlement by supporting existing services. In this regard, St Philips notes that Growth Option 4 (Sustainable Travel and Economy) would provide “a balance of growth at existing main settlements…and more modest growth in smaller settlements, which can contribute to enhancing the viability of village centres and provide affordable housing” (page 69). St Philips therefore considers that Stockton should not be disregarded from inclusion in Growth Options 2 and 4. Some of the spatial growth options have been brought forward from the Scoping Consultation, whilst others are hybrids of the previous options. St Philips considers that the current options should, in theory, allow the Issues and Options Consultation to consider how South Warwickshire could accommodate housing growth to meet its own housing needs, and a proportion of the C&WHMA and GBBHCMA’s unmet housing needs. However, St Philips believes that a mixed growth strategy, which combines several growth options, will prove to be the best growth strategy for South Warwickshire. In this regard, St Philips notes that the Sustainability Appraisal evaluates the 5 spatial growth options and concludes the following: “An overall best performing option is hard to identify. Option 5 is the worst performing option whilst Option 2 is likely to align most closely with development that will ultimately seek the most effective mitigation against climate change” (Para 7.15.2). The SA goes on to acknowledge that different options perform better for certain SA Objectives than others. It also cautions that the results are only a guide and the potential for mitigation has not been factored into the performance of the growth options (Para 7.15.1). The IO further notes that “that detailed locational information is not available and the ability to identify effects with precision is challenging” (Page 59). St Philips therefore considers that the SA is inconclusive regarding which option performs best. In this context, St Philips believes that the spatial strategy should not entail one particular growth option (i.e. developing in close proximity of rail corridors). It is considered that the five growth options interconnect, and in order to achieve the development needs within and beyond South Warwickshire up until 2050 a mixed strategy should be adopted. This would ensure a flexible and robust approach that would disperse the benefits of growth between all settlements within the South Warwickshire. Regardless of which growth strategy is pursued, St Philips considers that some development will need to be dispersed to ensure that the entirety of South Warwickshire benefits from housing growth. This is acknowledged within the Evolving the Spatial Growth Options Topic Paper (August 2022) which sets out how the 7 high level spatial growth options presented in the Scoping Consultation evolved into the 5 options presented within the IO. The Topic Paper acknowledges in relation to Option 5 that “even if this option were not taken forward, some limited growth might still need to occur in some smaller settlements to support the overall sustainability of these places” (Appendix 2). Therefore, although Option 5 does not perform comparatively well within the SA and Estimation of Emissions Study, St Philips considers that it will be necessary to disperse some growth to support the sustainability of smaller settlements. On this basis, St Philips considers that a mix of the Growth Options will promote sustainable patterns of development across the area and aligns with the sustainability aspirations that are set out in the NPPF. Whilst greater levels of development may need to be focussed around sustainable transport corridors, due to the level of infrastructure and services already present, it will also be necessary to direct growth to other settlements to ensure that the benefits of housing growth can be delivered in other parts of South Warwickshire. In particular, St Philips consider that there are several benefits to a mixed approach to the distribution of development: 1 It would support the well-being of those settlements that have the capacity to accommodate growth; 2 By concentrating development around existing and proposed new infrastructure it would also ensure that it benefits from a sustainable location with good access. Such an approach would allow the Council to capitalise on opportunities presented by existing or planned infrastructure when considering options for large scale new residential developments, in accordance with paragraph 73a of the NPPF; 3 When having regard to the need to release Green Belt land, such an approach would also be consistent with paragraphs 141 and 142 of the NPPF: Where amendments to Green Belt boundaries are required, the promotion of sustainable patterns of development should be considered, alongside giving first consideration to land which is (inter alia) well-served by public transport (Paragraph 142); 4 It can ensure that a sufficient supply of homes, within close proximity to existing and future employment opportunities, contributes to an efficiently functioning economy. This can also aid in minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions); and 5 It would enable growth to meet the needs of neighbouring authorities to be located in an area close in proximity to where these needs arise. Similar to the above, this also has the added benefit of minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions). Land at Jubilee Fields, Stockton: As set out in Section 1.0 of these representations, St Philips is promoting Land at Jubilee Fields, Stockton for residential development. The Site, encompassing an area of c. 1.57ha, is formed of a singular greenfield parcel and comprises arable agricultural land. The Site is rectangular in shape and is bounded by existing residential development to the north-west, a cemetery to the north-east and agricultural land to the south-east and south-west. It is well contained and is enclosed by established mature hedgerows and trees, except for the north-west boundary which borders residential properties. The Site is located on the southern edge of Stockton, a Category 2 Local Service Village, which is located approximately 2 miles north-east of Southam and 8 miles south-west of Rugby. Coventry, Daventry Leamington Spa and Warwick are located to the north, east, west and further west respectively. Bus services 63 and 64 connect the village to Leamington-Spa and Rugby. The Land at Jubilee Fields was included within the 2018 and 2020 Strategic Housing Land Availability Assessments [SHLAA] (Site Ref: STOC.08). Both SHLAAs concluded that the Site overall was ‘amber’, or ‘likely to be deliverable’. In essence, there are no known constraints on the site that would preclude development, subject to appropriate mitigation measures being put in place where required. The Site was also identified as a Reserve Housing Site within SOADC’s SAP Preferred Options Consultation (October 2020). This was subsequently followed by the SAP Revised Preferred Options Consultation (June 2022), where the site was no longer proposed for allocation. The most significant change to the revised document was the Council’s approach to reserved sites. Notably, given that work has commenced on the South Warwickshire Local Plan, the Council considers it is justified in focusing on identifying reserve sites that would be appropriate and deliverable to meet any housing needs that are identified in the short term. The site could provide approximately 1.57 ha of residential development, equating to approximately 35 new homes. The Vision Document, submitted in support of these representations, demonstrates that the Site could deliver a residential development in a sustainable location. The Site is surrounded by strong defensible boundaries, including existing residential development to the north-west and mature hedgerows to the south-east and south-west. St Philips consider that the Site presents an excellent location to deliver up to 35 dwellings, including 13 affordable dwellings. The scheme would be responsive to its surrounding, working with the Sites mature landscape features and protecting the rural character of the village. It is, therefore, a highly sustainable location for growth.

2. The Site and the Opportunity 2.1 The Site is located within the administrative boundary of WDC on the border with Coventry City Council (CCC), which is formed by Westwood Heath Road. 2.2 The Site is situated immediately to the south of Westwood Heath Road, to the north of Westwood Heath Road is the Network Rail Training Centre and an existing residential area, beyond which is Westwood Business Park. 2.3 To the west is Bockenden Road (which becomes Crackley Lane and links to Kenilworth), beyond which is housing allocation H42 ‘Westwood Heath’ which is subject of a hybrid Planning Permission (W/17/2357) dated October 2018 for a total of 425 dwellings, a convenience store of up to 400m2 and associated infrastructure. The first phase of development (129 dwellings) formed the detailed aspect of that application, which Crest have now commenced. This was followed by the submission of a reserved matters application (ref. W/21/1280) in July 2021 for details of appearance, landscaping, layout and scale for the remaining phases 2, 3 and 4 (296 dwellings), which is currently awaiting determination. 2.4 Further west is the settlement of Burton Green, which has residential properties along Cromwell Lane. To the south is open countryside and the former railway line along which HS2 is to be constructed. To the east is open countryside, allotments, playing fields and further east, the University of Warwick campus. Background The Site and safeguarded land 2.5 The Site forms part of a wider area removed from the Green Belt and ‘safeguarded’ by Policy DS21 and allocation S1 (land south of Westwood Heath Road) in the adopted WDC Local Plan (September 2017). 2.6 Policy DS20 ‘Directions for Growth South of Coventry’ states that: “The area to which this policy relates will be subject to an early partial local plan review within five years of the date of adoption of the plan. This will allow the Council to address any additional evidence regarding the need and potential for development in this area and in particular to ascertain whether necessary infrastructure has become available to allow safeguarded land to be brought forward to meet local housing need, should additional housing be required.” 2.7 Appendix B “Vision for the Land South of Coventry” of the WDC Local Plan (2017) stated: “This area will be a thriving, available and sustainable driver for economic growth, based around its excellent links to the strategic highways network, represented by a new link road from the A46 around the southern edge of the city, improved rail and other public transport connections serving the University of Warwick and the provision of significant opportunities for cycling and walking through and between the new areas of growth” 2.8 Specifically of relevance to any future housing development in this area, the vision states: “New housing developments will have created flourishing communities with their own individual characters, catering to residents throughout their lives and providing a range of attractive and well-designed properties. Residential development improves the quality of life of its inhabitants. It offers healthy and high quality living environments and provides a balanced mix of housing, community facilities, services and employment opportunities that have created a viable and sustainable community. Public perceptions of well-being and security are high, with residential areas designed to promote the safety of pedestrians, cyclists and residents of all ages and degrees of physical capacity. Layouts have been designed to be easily accessible to emergency services and incorporate high degrees of natural surveillance. Development respects and reflects a high quality natural environment. The landscape and biodiversity value of the area has been enhanced and protected, with precious woodland forming the heart of a system of conjoined and interlocking wildlife and habitat links bringing the countryside into the urban fringe. New habitats have been created and where existing resources were impacted by development, they have been replaced locally. Access to the natural environment is easily and safely available, with the provision of parks, informal open space, play areas, leisure and sporting facilities an integral aspect of all forms of development.” 2.9 The Site is removed from the Green Belt and safeguarded, with the future allocation to be made in the context of the review of the Local Plan. 2.10 It is considered that the suitability of the Site for residential development has already been tested through the due process followed through the examination of the adopted WDC Local Plan (2017). We are envisaging that the Site will come forward for allocation within the South Warwickshire Local Plan (SWLP). 2.11 It is important to note that the Issues and Options document does not refer to the safeguarded land previously identified in the adopted WDC Local Plan. However, the table at Chapter 12 confirms that Policy DS21 “Safeguarded Land” will be addressed in the Part 1 plan due to it being considered a strategic policy for the SWLP. We discuss this further in section 3 of these representations. South Coventry Masterplan 2.12 At WDC’s Cabinet Meeting on 20 April 2022, Members agreed to the Council progressing the masterplanning work, alongside key partner organisations (CCC, WCC, and University of Warwick), for the area to the north of the District and immediately to the south of Coventry, the plan enclosed at Appendix 2 demonstrates the extent of the masterplan area. The South Coventry Masterplan would effectively see HS2 become the new Green Belt boundary. 2.13 The purpose of the masterplanning process will be kept under review by all the participants. However, as set out in the report to Cabinet, officers expect that it will continue to perform an important role as follows: • To map and understand the various planned and emerging developments in the area; • To explore how to maximise community benefits including through improvements to green and blue infrastructure and connectivity; • To assist partner organisations in preparing their own masterplans for specific sites and to reflect their aspirations in the wider planning of the area; • To understand how the climate emergencies declared by WDC, Warwickshire County Council (WCC), the West Midlands Combined Authority and the University of Warwick should inform the future planning of this area; • To provide a focus for considering how best to engage with HS2 in terms of how this project can bring improvements to the area (including by linking with the HS2 Context Integration Study); • To provide a context for considering travel and transport improvements in the area, which should prioritise active and sustainable travel but also consider the purpose, justification and business case for the A46 Strategic Link Road; • To provide a framework and rationale for future business cases and bids to deliver transport infrastructure projects (e.g., road, VLR, South of Coventry/University of Warwick Railway Station);and • To enable, subject to wider work on growth options across South Warwickshire and any agreement within the SWLP as to the development strategy, consideration of whether, where and how this area may be suitable for further growth as part of the Local Plan. 2.14 Given that the Site forms part of the wider masterplan area IM Land support this exercise and have confirmed that they would be willing to partake in any discussions at a suitable stage. 2.15 The ongoing masterplanning work is a clear indication that growth to the south of Coventry is supported by the Councils. Furthermore, IM Land have prepared a Wider Masterplan working with CEG to illustrate how the safeguarded land at Westwood Heath can be delivered as an allocation as part of the South Coventry Masterplan proposals, which is included within the Vision Document at Appendix 3 of these representations. We will continue to work with WDC and WCC, taking an active role as this workstream progresses. A46 Strategic Link Road – Engagement with WCC 2.16 As described above, part of Policy DS20 (Directions for Growth South of Coventry) refers to “proposals should take account of the potential for a new link road, which has been identified as an important means of mitigating increased traffic flows on the local and strategic road network; increasing existing strategic highway capacity; and providing an improved future strategic highway link to UK Central”. It also features in the Vision for land south of Coventry in Appendix B of the adopted Local Plan. 2.17 The A46 Strategic Link Road is being promoted by WCC along with CCC; WDC; Coventry and Warwickshire Local Enterprise Partnership; and, Department for Transport (DfT). 2.18 The Strategic Link Road aims to improve accessibility to the University of Warwick and the surrounding Business Parks and other employment areas through the provision of a new road linking the A46 at Stoneleigh Junction with Westwood Heath. It will also help reduce the inappropriate use of minor roads such as Crackley Lane for traffic wishing to access the University and surrounding area. 2.19 WCC previously consulted on the three main options for the Strategic Link Road from 30 November 2020 to 14 February 2021. Turley submitted representations on behalf of IM to this consultation setting out concerns that the three potential options for access onto Westwood Heath Road were all located on the Site – rather than being dispersed across the wider frontage of Westwood Heath Road. A copy of these representations is enclosed at Appendix 4. 2.20 Since submission of representations in February 2021, IM and CEG, have been in discussions to agree the most appropriate access point for the link road onto the Westwood Heath Road. he current iteration of this is shown on the Wider Masterplan within the Vision Document (Appendix 3). This plan has been shared with WDC and WCC. 2.21 The responses to the A46 Strategic Link Road consultation were analysed and considered at WCC’s Cabinet on 14 October 2021. The Cabinet report confirmed that feasibility works were ongoing and an Outline Business Case for the scheme was being compiled for submission to the DfT, which would make the case for the scheme and request continued support from the Government. 2.22 The Outline Business case was originally intended for submission to the DfT in Autumn 2021. However, CCC and WCC, in full consultation with Warwick and Stratford District Councils, took the decision to defer the application for the DfT’s Major Road Network (MRM) / Large Local Major (LLM) programme funding by two years. We understand that the Councils consider that a future MRN / LLM funding submission will feature the submission of a business case for investment in a wider transport package of measures, including the A46 Link Road as appropriate. It is anticipated that the South Coventry Masterplan will incorporate the wider package of measures, and help support the future business case. The Opportunity 2.23 A Vision Document for the Site is enclosed at Appendix 3 of these representations, which demonstrates the Site’s ability to deliver new homes in a sustainable location, within the early stages of the plan period, independent of the wider safeguarded site and wholly aligned to the five pillars of the SWLP. 2.24 The latest concept masterplan for the Site, included within the Vision Document, provides the following key design principles and development benefits: • The proposed development comprises 3.7ha of residential development, amounting to approximately 130 dwellings at a density of 35 dwellings per hectare (dph). • The development incorporates an area for the potential 2FE primary school site located predominantly within the adjacent land to the south forming part of the wider site area. • The proposed development retains existing hedgerows along the north, west and east site boundaries and includes enhanced new public open space with new trees and landscape planting. New public open space within the development includes a central green space as well as a landscaped western green edge. This will aid social interaction and integration. In addition, this increases exposure to green spaces, enhancing health and wellbeing. • The sustainable urban drainage strategy on the Site incorporates a new attenuation pond in the south west corner at the low point of the Site. This will also add an attractive feature to the public open space in this area. • The development has been designed to be incorporated within the potential wider masterplan for the area, with potential to make appropriate connections and increase permeability and accessibility. • The development includes a clear hierarchy of roads to create a legible street pattern, to assist in way finding. • The Site will be planned comprehensively as part of the overall safeguarded area, which will include the new A46 Link Road route and an additional access to the Site from the south. • There will be a 10% Biodiversity Net Gain provided across the safeguarded wider site area which the Site will contribute to. Sustainability Credentials 2.25 The sustainability credentials of the Site and the proposed development have been assessed, with full details included within the Vision Document at Appendix 3, and the Site will assist with the following policy aspirations: • Climate emergency – The development will endeavour to meet the Climate Emergency Action Programme released by WDC following the Council’s pledge to become net zero carbon by 2030. • Future Homes Standard – The development will align, as appropriate, with the interim Future Homes Standard (FHS) requiring a 31% reduction in CO2 emissions over Part L 2013 or the full FHS from 2025 requiring homes to achieve a 75-80% reduction in CO2 emissions. • NPPF – The development will meet the objectives of the NPPF: ‒ Building a Strong and Competitive Economy; ‒ Promoting Sustainable Transport; ‒ Delivering a Wide Choice of High Quality Homes; ‒ Requiring Good Design; ‒ Promoting Healthy Communities; ‒ Meeting the Challenge of Climate Change; ‒ Conserving and Enhancing the Natural Environment; and ‒ Sustainable Waste Management • SWLP – The development will endeavour to: ‒ Increase accessibility and reduce private car travel; ‒ Increase energy efficiency; ‒ Support renewable energy use; ‒ Design for climate change mitigation and adaptation; ‒ Mitigate flood risk; and ‒ Mitigate biodiversity loss & maximise opportunities for enhancement.

Question S4.1 3.13 IM support the growth of existing settlements as part of the overall strategy. 3.14 The area to the south of Coventry was identified as a location for growth through the adopted WDC Local Plan (2017). Therefore, safeguarded sites in this location should be amongst the first to come forward within the SWLP. Further growth to the south of Coventry is clearly supported through WCC and WDC’s work to create a masterplan for this area.

Question S7.2: 3.17 In relation to the growth options, IM consider that it would reasonable and logical to consider a range of growth options, specifically due to the quantum of development that is required throughout the plan period. 3.18 The Site that is the subject of these representations logically falls within Option 2 (Sustainable Travel) and Option 3 (Economy). It is considered that locating development adjacent to existing urban areas can ensure that growth is focused on the most sustainable locations, where facilities and connections are already available. Furthermore, such developments can then come forward within the early stages of the local plan to ensure a pipeline of housing sites. 3.19 As set out in our response to question S10, below, The Site has previously been determined by an inspector to be suitable for future sustainable development through the examination of the adopted WDC Local Plan (Adopted 2017), and subsequently removed from the Green Belt and safeguarded for development. Therefore, to support the growth options set out above, land that has been previously safeguarded for development should receive allocations within the SWLP, to be brought forward within the early stages of the plan period.

Question S9: 3.20 IM consider that the Part 1 Plan should review and re-assess all settlement boundaries to consider the most sustainable pattern for housing growth, including the land south of Coventry. This will require the removal of land from the Green Belt, and is therefore a strategic matter for consideration within the Part 1 Plan.

3.21 IM generally support the broad vision and strategic objectives for the distribution of development set out in the Issues and Options document. However, to meet this vision, it is important to ensure that growth is distributed towards the most sustainable locations. When considering the proposed growth options 2 (Sustainable Travel) and 3 (Economy), the most appropriate locations for growth are those adjacent to existing urban areas, such as the land directly to the south of Coventry, where facilities and connections are already available, which includes the currently safeguarded land off Westwood Heath Road. 3.22 Sites which are safeguarded in the adopted WDC Local Plan (Adopted 2017) have already been determined by an inspector to be suitable for future sustainable development potential and therefore removed from the Green Belt. The safeguarded land at Westwood Heath Road, should be allocated through the SWLP to ensure a pipeline of housing sites and enable the delivery of new homes in the early stages of the plan period. 3.23 The findings of the Sustainability Appraisal prepared in support of the adopted WDC Local Plan (2017) supported and resulted in the allocation of the Site as a safeguarded site within the plan. This clearly supports the Site as a sustainable location for growth and should therefore be recognised and referenced through the updated evidence-based documents for the SWLP. It is also considered that the Sustainability Appraisal for the SWLP should account for sufficient mitigation, in order to accurately identify the most appropriate options. 3.24 Further growth to the south of Coventry is also clearly supported through WCC and WDC’s work to create a masterplan for this area, as detailed in the introduction section of these representations. Therefore, to support the ongoing masterplanning work and ensure consistency between the Councils’ workstreams, the allocation of the Site through the SWLP represents a sensible and logical approach.

1. USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: The proposed development in Henley-in-Arden uses development in the Green Belt incorrectly to resolve structural planning problems in the district. Henley lies between two much larger urban developments in a section of Green Belt land which serves to prevent urban sprawl extending such that the developed envelopes extend to such an extent that they join. To the south, there is extensive white space on the outskirts of Stratford upon Avon, for example, which is ideally suited to development that meets the needs of a modern economy that is responsive to the environmental demands and the new working patterns that have emerged as imperatives in recent years. Development of brownfield sites around existing urban envelopes is consistent with modern planning policy that co-locates living, working and leisure spaces, and preserves the integrity of the nearby Green Belt and all of its benefits. Stratford District Council itself highlights the evidence that supports this argument: “Unemployment across the District is low, with 0.3% of workers claiming jobseekers allowance in May 2016. This is lower than the UK average (1.8%) and West Midlands average (2.2%). There is an imbalance between the number of jobs in the District and its working population. An increasing number of residents commute to higher paid employment outside the District, while lower paid jobs are often filled by people coming into the District from adjoining areas. These commuting patterns impose significant pressures on the road network. Employers in and around Stratford-upon-Avon can struggle to recruit staff into lower paid and part time roles and cite the absence of affordable commuting options, particularly outside of peak travel times, as a barrier to filling vacancies.” 2. ERODES THE COMMITMENT TO THE PRESERVATION OF THE GREEN BELT The West Midlands Green Belt wraps around Birmingham, the Black Country and Coventry and extends to a ring of towns beyond the conurbation. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch (apart from small areas of land to the west of Mappleborough Green), Bromsgrove, Solihull and Warwick. The settlements of Alcester, Henley and Studley are excluded from the Green Belt. Commitments from Stratford and Warwick in the existing planning frameworks reiterate a commitment to the integrity of the Green Belt and the prevailing government guidance and policy in respect of the Green Belt. It is critical that the Green Belt around Henley is preserved for its environmental benefits and the health and social benefits that it brings to residents. The proposed development is inconsistent with commitments made in the existing planning policies. 3. SIGNIFCANT INFRASTURCTURE LIMITATIONS AND CONSTRAINTS Traffic Limitations: Existing Plans to Match funding has been secured to calm traffic on the High Street in an initiative to impose during the first six months of 2023 a 20 mph speed limit on the High Street and commuter ‘rat run’ cul de sac roads that lead off the main artery. It is counterintuitive to simultaneously restrict the flow of traffic through the town – a demonstrated need in response to recent traffic safety issue – and at the same time expand the volume of traffic resulting from increased housing development around the town. Poor Bus Links: The bus and train infrastructure is barely sufficient to sustain the existing population, before considering an additional 2,000 residents which might result from the proposed development. The X20 bus service runs 12 buses a day on a weekday and covers the North – South route between Stratford and Solihull. Bus passengers requiring to travel East – West to Redditch and Warwick are required to travel to the end of the north or south routes and then change to another service. Stratford District Council agree – the 2018 SDC Transport Strategy reports that “A key barrier to bus use is journey length and issues of punctuality and service reliability which are exacerbated in Stratford-upon-Avon by congestion”, which is central to the operation of any bus routing to service Henley-in-Arden. Further, SDC reports that “bus passenger facilities … are currently insufficient for the volume of passengers….”. Impact of Closure of the M40 and other Congestion: With the current level of housing, any closure of the M40 south of the M42 junction leads to the diversion of traffic off the motorway and through the town, predominantly using the north-south axis along the High Street. Statistics show that the M40 is the subject of a temporary closure between 3 and 4 times a year. Roadworks anywhere in the town – typically driven by servicing the antiquated drainage system and other infrastructure – currently creates significant delays in the town. Additional development will have an adverse impact on the existing street scape within Henley. Inability to Expand or Widen Existing Roads to Accommodate Traffic: Henley-in–Arden is a medieval market town with a strong architectural heritage reflected in the North – South road axis and the listed buildings which line the A3400 and High Street. The listed buildings which exist along the main roads in the town preclude any expansion or widening of the road to accommodate increased volumes of traffic arising from increased development and volume of housing. Road Safety: An increase in development in or around Henley-in-Arden will lead to an increase in traffic of all modes to service population movement around a market town based around two intersecting roads. A brief review of the traffic accident statistics for Henley in Arden for the last five years shows 25 incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all of which centre on the High Street and the crossroads at the South of the town. An increase in population of the scale proposed by the draft Plan would inevitably lead to an increase in road traffic casualties. Car Parking: Car parking is an acknowledged problem in Henley-in-Arden, where the existing historic housing prevents the development of extensive car parking and on-street parking on the High Street predominates and cars have been forced into small off-street parking facilities – such as that behind the Co-op store. The proposed plan makes no accommodation for the resultant car traffic that would be generated by extensive development around the town. Air Quality and the Environment: Development of the scale proposed will have a disproportionate and adverse impact on air quality and other factors driven by additional traffic from the aggressive development proposed by the town. Propensity to Flooding: Henley-in-Arden is famously susceptible to flooding, and certainly more so than other sites and locations proposed in the plan. The SFRA highlights that Henley is one of the most sensitive areas in the Stratford District to the fluvial impacts of climate change. The town rests at the base of a hilly catchment area providing an obvious outlet for when the River Alne floods, as it did most notably in memory in 2007. Additional development would increase the impact of that flooding and place greater demands on the surrounding environment in the event of flooding. No Potential to Future Proof the Infrastructure: There is no obvious solution to the problem of future-proofing any development proposed in Henley-in-Arden. Ageing water and sewerage infrastructure means that there is little chance of expansion or the development of the infrastructure of the future, particularly electric charging points for cars and the support of renewables. 4. LOCAL SERVICES ARE INADEQUATE TO SUPPORT PLANNED EXPANSION: An increase in the housing stock in Henley-in-Arden such as that proposed in the draft Plan would require additional infrastructure investment, most obviously in schools and medical facilities. Henley in Arden School is part of the Arden Multi-Academy Trust. It has a capacity of 700 pupils and yet already has 710 pupils enrolled. Expansion would inevitably be necessary to sustain development of the extent proposed and local government would need to provide funds. The existing medical practice moved from the High Street to the existing site in 1990, and access is via a footpath from the High Street or via car through a housing estate to a council run car park. Again, the site of the existing facility and the lack of potential for expansion into surrounding space means that expansion in Henley-in-Arden would require a new medical facility in a new location. Any expansion of either of these facilities or the commission of new sites would inevitably lead to an increase in the risk of road, pedestrian and traffic incidents as a direct result of the crossroads and road configuration which dominates the town. 5. ABSENCE OF A FOCUS ON LOCALISM: The outline proposals make no reference to even the sense of the principles of localism in the Henley-in-Arden community and run contrary to local sentiment. Those responsible for the development of the plan must provide opportunities for communities to influence decision-making. support placemaking and. deliver services that reflect local requirements. The scale of the development proposed is completely inconsistent with the scale of the existing town and the development of the population to date. Between 1975 and 2015, the population of Henley grew by 14.3%, and grew even more strongly in later years where between 2000 and 2015, it grew by 10.2%. Using data and projections from 1. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Center for International Earth Science Information Network), the population in 2022, stood at 2,571. Assuming an average of 3.5 heads occupying a lower estimate of 500 additional houses in Henley-in-Arden as proposed in the Plan, the population of the town would grow by 68%, which is completely disproportionate development. The plan ignores Stratford Council’s own observations about the importance of Henley’s heritage and the impact of further development upon it. The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan of September 2022 observes that “The setting of some of (the) assets, particularly the castle and church, are still currently experienced within the historic open agricultural landscape. It is therefore recommended that development of the land beyond the north-eastern edge of the settlement should be avoided.” There are also similar observations about the land to the south-east and south-west of the town which are completely contrary to the scale of the development proposed in the plan. Similarly, there is little consideration of the sites north of the Warwick Road (reference HEN.02 in the Stratford Heritage Assessment) where the RED assessment risk of both harm to surviving Ridge and Furrow and harm to archaeological monuments runs contrary to the proposed sites offered for development to the East of the town. The economy of Stratford upon Avon is delicately dependent on visitors and those in search of rural tourism – the strength of demand is such that the town has its own Heritage Centre for visitors and queues for the locally-made ice cream regularly generate queues that extend up the High Street. Extensive development of the type which is proposed would likely jeopardise local businesses and a tourism-centred town: Solihull was originally a pleasant town in the Green Belt – literally ‘Urbs in Rure’ – but development without reference to local concerns has let it evolve into something much different. 6. INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable. References: 1. Traffic calming: https://www.stratford-herald.com/news/henley-in-arden-to-get-20mph-speed-limit-along-high-street-9280462/ 2. Bus Frequency: Stagecoach timetable 3. Traffic accidents: https://www.crashmap.co.uk/Search 4. Bus Infrastructure: https://www.stratford.gov.uk/doc/206646/name/Adopted%20Stratford%20Area%20Transport%20Strategy.pdf 5. Impact of Traffic on Environment: https://www.stratford.gov.uk/doc/206646/name/Adopted%20Stratford%20Area%20Transport%20Strategy.pdf 7. SFRA: https://www.stratford.gov.uk/planning-building/water-and-flood-risk.cfm

2.1 This section describes the opportunity of the site in terms of its geography and its prospects for delivering a new neighbourhood at North Leamington. Description of the Site 2.2 The Site is within the administrative boundary of Warwick District Council (‘WDC’) and within the Old Milverton and Blackdown Neighbourhood Plan Area; and Royal Leamington Spa Neighbourhood Plan Area. 2.3 The WDC Local Plan 2011 – 2029, adopted in September 2017, confirms within its Proposals Map that the Site is within the Green Belt (Policy DS18) and is not allocated for residential development. 2.4 The Site, currently comprising agricultural fields, is 73ha and is located to the northern boundary of Royal Leamington Spa, 1.2km east of the Village of Old Milverton (direct measurement from the centre of the Site to the Church). Much of the land is currently used for arable uses and each of the field parcels are divided by well-established hedgerows and individual mature trees. There are also existing community allotments at the southern boundary of the Site adjacent to existing residential properties. 2.5 The northern boundary is bound by Sandy Lane, which merges into Old Milverton Lane to the east as it joins the Blackdown Roundabout. A farmstead with a cluster of buildings (‘Quarry Cottage’) sits outside of the northern boundary. Immediately north of the Site boundary, beyond Sandy Lane is mainly fields that are bounded by the River Avon, as well as Quarry Park Golf Course and a number of healthcare facilities towards the east, off Old Milverton Lane. 2.6 Two fields are located along the western boundary, divided by a footpath and defined by a tree and hedgerow belt adjacent to the railway line. The southern boundary is demarcated by residential properties. Access to the Site can be obtained via the public footpath from Guys Cliffe Avenue at the south western boundary. 2.7 Kenilworth Road (A452) largely defines the Site boundary to the east, with a remaining portion of the boundary defined by a cluster of residential properties. 2.8 Taylor Wimpey control, by way of a development option, the entirety of the land edged in red on the Site Location Plan (enclosed at Appendix 1). Background 2.9 The Site was promoted through the adopted Local Plan and WDC during the suspension of the examination, identified part of the site for a housing allocation (250 dwellings) and a ‘Park and Ride Area of Search’; and the larger part of the site as safeguarded land (circa 1000 dwellings). The Inspector, in his Report dated July 2017, stated: “During the suspension of the examination, the Council proposed removing land from the Green Belt North of Milverton, on the edge of the urban area of Leamington Spa for a housing allocation and safeguarded land. The estimated capacity of the housing site was 250 dwellings and the safeguarded land some 1,000 dwellings. Development of the land in question would involve a substantial expansion of the builtup area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact of the openness of the Green Belt and the character and appearance of the area. As with the Red House Farm site and for the same reasons, the site North of Milverton does not need to be allocated in order to ensure that the District’s housing requirements are met or that a five year supply of housing land is provided for. Sufficient housing land would be available elsewhere in and on the edge of the urban area of Leamington Spa, Warwick and Whitnash outside of the Green Belt. Exceptional circumstances to justify altering the boundary of the Green Belt and allocating the site for housing do not exist. Given that the boundary of the Green Belt around Leamington Spa, Warwick and Whitnash would remain otherwise unaltered, it would be unnecessary and inappropriate to identify safeguarded land at this point in time. A longer term strategy for locations of growth around the urban area and District generally could be considered as part of a review of the Local Plan. There is no need to modify the submitted Local Plan as suggested by the Council therefore.” 2.10 Following the Inspector’s comments the site was removed from the Local Plan, for all aspects of the allocation. Other than a small Green Belt release to the north of Cubbington, there were no further Green Belt releases around Warwick or Leamington. 2.11 The Inspector’s Report (July 2017) to the WDC Local Plan also stated, at Paragraph 83: “Given the nature of the District and its settlements, there are limited areas of previously developed land with potential for development, for example there are no large areas of former industrial land”. It is therefore considered that some Green Belt release to accommodate the minimum housing requirement is required through the SWLP. 2.12 Due to the quantum of growth required to support the minimum housing requirement (both market and affordable) for the South Warwickshire area and the associated need for larger scale development (NPPF, 139), it is considered that exceptional circumstances now exist to justify altering the boundary of the Green Belt and allocating this site for residential development within the SWLP. The technical evidence supporting the proposed development at Land North of Leamington demonstrates that the consequences of releasing this site from the Green Belt would constitute sustainable development. 2.13 The Inspector’s comments relating to openness of the Green Belt and character and appearance of the area would be associated with any large-scale development within the Green Belt. Consequently, the current proposals for the Site have been underpinned by a technical evidence base which demonstrates that the Site can be landscape led and delivered in a truly sustainable manner. 2.14 Taylor Wimpey would be pleased to continue to work with the South Warwickshire Councils throughout the emerging SWLP to further develop the proposals. The Opportunity 2.15 The Site offers a unique opportunity to deliver a high-quality, deliverable, and viable urban extension to Royal Leamington Spa in a sustainable manner. 2.16 As the proposals for the Site have been examined in public for the now adopted WDC Local Plan, Taylor Wimpey are keen to continue to discuss the Site’s opportunities with the SWLP authorities and key stakeholders and seek their inputs to continue to evolve the masterplan, which will be submitted to future stages of the SWLP. The current Site Concept Masterplan is provided at Appendix 2, which has been carefully informed by the discussions with WDC to date. 2.17 The Vision Document enclosed at Appendix 3 provides further detail on the technical evidence for the Site and sets out Taylor Wimpey’s environment strategy ‘Building a Better World’. Five key design principles have also been identified that will guide the future proposals for this site, they include: • Design Principle One: Environment & Sustainability – Striving to achieve climate resilient & net zero carbon development, including new homes and potential new employment space set within vibrant, distinct and accessible places. • Design Principle Two: High Quality Design – Creating well-designed & beautiful places which responds to local context. • Design Principle Three: Safety – Ensuring improvements to health, safety, wellbeing and quality of life are at the heart of the new community. • Design Principle Four: Connections – Connecting people to places which prioritise walking and cycling, aligning with the ’20-minute neighbourhood’ concept to encourage sustainable movement and commuting options. • Design Principle Five: Biodiversity – Protecting and enhancing biodiversity & environmental assets and resilience, including over half of the site being designated for open space and natural habitat areas. 2.18 The Concept Masterplan (at Appendix 2) demonstrates how the following could be delivered at the Site: • Approximately 1,200 new homes (at around 38 dwellings per hectare) designed to accommodate a range of housing with a mix of house types, tenures and sizes to meet identified local needs. • Potential provision of a mixed-used community hub/centre and a 2 form entry primary school. • Potential Hospital Extension / employment land (2ha) on the north eastern boundary of the site • Potential main vehicular, pedestrian and cycle access from Kenilworth Road, with sustainable transport links including bus re-routing into the Site. With secondary access onto Sandy Lane. • Opportunities to connect to planned cycle improvements along the Kenilworth Road, providing a connection between Leamington Town Centre and Kenilworth. • Potential emergency, cycle and pedestrian access point onto Guys Cliffe Avenue. 2.19 Potential to provide approximately 38ha of structural landscape and public open space. The significant public open space can include sports pitches, play provision, allotments, community gardens and sustainable drainage features. Taylor Wimpey would welcome the opportunity to continue to discuss these emerging proposals with WDC and SDC in the near future.

Question S1: • Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced 3.7 Taylor Wimpey agrees with Option S1a, for the SWLP to take a proactive approach and seek to identify Strategic Green and Blue corridors now, in advance of the Local Nature Recovery Strategy. This will help to identify where those links can be created from the offset, determining a growth strategy that increases biodiversity and supports nature recovery across the plan area, as noted within the Issues and Options document. This approach is supported by the Warwickshire, Coventry and Solihull sub-regional green infrastructure study (2013) and the Preliminary Habitat Regulations Assessment Scoping Report (November 2022). 3.8 As suggested by the Issues and Options, the incorporation of these corridors can then be specifically addressed through the future Local Nature Recovery Strategy and a dedicated policy under the Part 2 Plan.

Question S4.1: of the overall strategy? 3.9 Yes, Taylor Wimpey agrees with the following statement from the Issues and Options (Issue S4) that: “… in deciding upon the best distribution strategy for new development within South Warwickshire it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements, potentially alongside and in combination with other options such as new settlements” 3.10 Directing growth to existing settlements provides an opportunity to deliver sustainable development whilst meeting local housing needs. Leamington is the largest town within the SWLP area, with a significant number of facilities and employment opportunities and is capable of accommodating significant growth over the plan period. Further, Leamington Spa is identified within all 5 growth options. 3.11 This assertion is based on a review of the existing evidence base supporting the Issue and Options, which concludes the following for Leamington Spa: Urban Capacity Study (October 2022) 3.12 The identification and release of greenfield and Green Belt sites is particularly pertinent, given that available brownfield land is limited in its ability to accommodate South Warwickshire’s growth needs over the plan period. This focus beyond brownfield land is supported by the findings of the Urban Capacity Study (October 2022), which concludes that whilst urban sites and existing commitments could allow the SWLP to meet some of its housing needs, “it is unlikely to be possible to meet current development needs without significant greenfield development”. Specifically, the Study states that only a potential housing supply of around 6,145 dwellings could be accommodated within existing urban boundaries (plus a further 3,400 dwellings if all publicly accessible car parks across South Warwickshire were consolidated and partly redeveloped). Sustainability Appraisal (SA) Issues and Options Stage (November 2022) 3.13 The SA has tested the five proposed Growth Options, which provide details of whether housing and employment development should be distributed at a strategic scale across the SWLP area. Leamington Spa is included within each of the Growth Options. 3.14 The SWLP and SA then identified 32 broad locations which represent options for up to 2,000 homes located around the main settlements. The main settlements, which included Leamington Spa, were identified as those being within a 20 minute walk or 10 ride (approximately 800m in any one direction) from key services such as public transport access point, (train station or bus station), GP surgery, a primary school, or supermarket. Of the 32 broad locations, 6 of these were located around Leamington Spa, including land at North Leamington (‘B.13 Royal Leamington Spa Northwest’). 3.15 Table 4.8 of the SA sets out a conclusion of the overall assessment for each of the 6 Leamington Broad Locations, with paragraph 4.8.1 stating that there is ‘no clear best performing broad location’. As set out above, it is important to note that the SA has not considered any proposed mitigation for each location. 3.16 From a review of Leamington Broad Locations, firstly in respect of the SA rankings, it is indicated at this stage that all locations scored equally well (major and minor positive impact) in respect of housing provision and access to PRoW/cycle path, primary school, Further Education and employment opportunities. On the other hand, all broad locations scored poorly (major and minor adverse impact) in respect of potential carbon footprint, landscape character impacts, Agricultural Land Classification, location within a Mineral Safeguarding Area, and potential increases in household waste generation. 3.17 Most of these broad locations, including Land North of Leamington, are currently located within and would require release from the Green Belt, save for the two broad locations furthest south of Leamington (SA Refs. B.14 and B.16). A summary analysis of these broad locations and the key findings of the evidence base (including the Sustainability Appraisal) is set out at Appendix 4. 3.18 Specifically in respect of Land North of Leamington, the Site is not subject to any notable environmental or physical designations or constraints (other than Green Belt) and scored as the best performing site in respect of: Biodiversity and Geodiversity; Landscape; and Education. Adding to this, the provision of site-specific mitigation and supporting facilities on site would enhance the score for the Site even further, particularly in respect of landscape, biodiversity and pollution impacts, and potential access to leisure facilities, a GP surgery and a food store. 3.19 Furthermore, Land North of Leamington scored particularly well in the SA in respect of its access to an NHS Hospital, bus stops, greenspace, and a railway station. Specifically, the Site is located less than 2.5km from Leamington railway station, the second closest of all 6 broad locations around Leamington and is also less than 3km from Warwick railway station. Settlement Analysis (January 2023) 3.20 Royal Leamington Spa is designated as a ‘Main Town’ and amongst the most sustainable ‘first tier’ settlements, alongside Warwick, Stratford-upon-Avon, Kenilworth and Whitnash. Further to this, Table 1 demonstrates that only Leamington and Stratford-upon-Avon are relevant to all growth scenarios originally identified in the SWLP Scoping Consultation document (May 2021). 3.21 The Settlement Analysis reviews the existing connectivity, landform and density position for Leamington Spa. Land at North Leamington is assessed as ‘Area 8’ within the mapping for ‘Cubbington and North Leamington’ which are set out at Appendix 1 of the Settlement Analysis. 11 3.22 The mapping for ‘Cubbington and North Leamington’ confirms the following: • Connectivity: The site benefits from a connectivity grade of C, demonstrating connections to at least one secondary street and possible connections to active links and a loop road or cul-de-sac, with barriers which may be overcome. The site’s connectivity grade C is the joint best grade of any area around Royal Leamington Spa, with most other areas falling under the poorer connectivity grade D. Specifically, the site benefits from an immediate connection off at least one primary street (Kenilworth Road), a loop road (Vernon Close) and a public footpath. • Landform Analysis: The site benefits from relatively flat topography and no Flood Zone or green infrastructure constraints. Therefore, there are no significant gradients that have the potential to impact on the ability and/or likelihood of using active modes of travel for some trips nor are there areas at risk of flooding which have the potential to impact movement and route options. • Local Facilities within 800m: Local facilities are also located within 800m walking distance of the site, including those relating to retail, jobs and economy; open space, leisure, recreation – well-being; and education. • Density: The existing settlement density adjacent to the site is also characterised as the ‘outer suburb’, providing between 20 and 40 dwellings per hectare, demonstrating that the development of the Site would align with the densities of the surrounding areas. 3.23 Through the masterplanning exercise set out in the Vision Document (Appendix 3) Taylor Wimpey has demonstrated that there will be opportunities to enhance the connectivity scorings once suitable mitigation has been applied. It is considered that ahead of the Preferred Options stage of the SWLP, the settlement analysis should be reviewed to consider the impact on new development – with mitigation applied. Bus Accessibility Mapping 3.24 The Bus Accessibility Mapping (April 2022) supporting the SA demonstrates that Land North of Leamington is located within 0-15 minutes bus travel time of Royal Leamington Spa, Warwick and Kenilworth. These settlements are all designated as ‘Major Towns’, defined as locations for major retail and leisure. 3.25 Consequently, the site benefits from direct access within 0-15 minutes bus travel time to essential services and facilities, including employment centres, GPs, dentists and pharmacies, and secondary schools and colleges, and is within 15-30 minutes bus travel time of two hospitals.

Question S7.2: 3.28 A mixed approach, blending all growth options, is recommended in order to appropriately satisfy all of the development needs of South Warwickshire over the Plan period. 3.29 Land North of Leamington is identified and assessed favourably across all growth options listed above, and can be delivered appropriately in line with the five overarching principles of the Local Plan, namely, to ensure that South Warwickshire is climate resilient and achieves net-Zero carbon; well-designed and beautiful; healthy, safe, and inclusive; well-connected; and, biodiverse and environmentally resilient. Development of the Site is also supported by the SWLP evidence base including the SA, Settlement Design Analysis and Bus Accessibility Mapping, as set out previously in these representations. 3.30 The Site represents a deliverable large-scale opportunity and appropriate strategy for growth, which will significantly support the delivery of predominantly housing and also economic needs throughout the Plan period. The Site also holds the potential to support a range of other uses/supporting facilities to deliver a sustainable community (should there be an evidenced need), and would be complemented by suitable on-site mitigation measures, as set out in the response to Question S4.2 above. 3.31 Furthermore, following the analysis undertaken in support of the Local Plan and summarised at Appendix 4, Land North of Leamington presents the optimum broad location for growth around Royal Leamington Spa, and amongst the existing settlements across South Warwickshire as a whole. Delivery of the Site will also comprise a wide range of benefits, as set out previously in these representations.

Question S9: 3.32 Option S9b is the most appropriate option for South Warwickshire as there will undoubtably be a need to review and alter some existing settlement boundaries to accommodate the housing requirement up to 2050 on land adjoining existing sustainable settlements, including Royal Leamington Spa. 3.33 Option S9b is consistent with Paragraph 73 of the NPPF in that it will allow for the supply of large numbers of new homes to be delivered by significant extensions to existing villages and towns “provided there are well located and designed, and supported by the necessary infrastructure and facilities”. 3.34 This Part 1 Plan should carefully review and re-assess all settlement boundaries to consider the most sustainable pattern for delivering the development needs of South Warwickshire over the Plan period. Inevitably this includes the removal of land from the Green Belt, which currently inhibits some of the most sustainable locations for growth around existing settlements such as Royal Leamington Spa, presenting a strategic matter which must be dealt with as part of this Part 1 Plan. 3.35 In line with this approach, Land North of Leamington presents the most sustainable pattern for housing growth and should thus be accommodated accordingly through the respective review of the existing settlement boundary.

Question S10: 3.36 Aligned with our responses set out above, a mix of strategic approaches is needed to deliver the development needs of South Warwickshire. This should include focusing development around existing settlements to ensure suitable future growth, particularly in the most sustainable locations such as Royal Leamington Spa. A review of existing settlement boundaries and Green Belt is needed to accommodate this growth. 3.37 Land North of Leamington presents a suitable strategic scale opportunity to significantly deliver South Warwickshire’s housing and employment needs. This will include social, economic and environmental benefits centred around the five design principles for the site, as set out above and in the Vision Document (Appendix 3), alongside any appropriate mitigation measures deemed necessary.

4.3 The Concept Masterplan and Vision Document (at Appendix 2 and 3 respectively) demonstrates how the following could be delivered at the Site [Land North of Leamington]: • Approximately 1,200 new homes (at around 38 dwellings per hectare) designed to accommodate a range of housing with a mix of house types, tenures and sizes to meet identified local needs. • Potential provision of a mixed-used community hub/centre and a 2 form entry primary school. • Potential Hospital Extension / employment land (2ha) on the north eastern boundary of the site • Potential main vehicular, pedestrian and cycle access from Kenilworth Road, with sustainable transport links including bus re-routing into the Site. With secondary access onto Sandy Lane. • Opportunities to connect to planned cycle improvements along the Kenilworth Road, providing a connection between Leamington Town Centre and Kenilworth. • Potential emergency, cycle and pedestrian access point onto Guys Cliffe Avenue. 4.4 Potential to provide approximately 38ha of structural landscape and public open space. The significant public open space can include sports pitches, play provision, allotments, community gardens and sustainable drainage features. Taylor Wimpey would welcome the opportunity to continue to discuss these emerging proposals with WDC and SDC in the near future.

Q-S7.2: We consider that Options 1, 2, 3 and 4 represent appropriate growth options as they would support sustainable patterns of development directing development to the main settlements, including Royal Leamington Spa. We believe that the spatial strategy should prioritise the main settlements in order to deliver the Vision, Strategic Objectives and 20 minute neighbourhood principle.

We consider that the allocation of the Site [Land at Red House Farm Black Lane Lillington Leamington Spa] for a residential development of circa 270 homes would achieve a sustainable pattern of development that can positively contribute to meeting the development needs of South Warwickshire and align growth and infrastructure; improve the environment; and mitigate climate change and adapt to its effects. The Site would contribute positively to the delivery of the emerging Vision and Strategic Objectives of the South Warwickshire Local Plan, as follows: - Meeting South Warwickshire’s Sustainable Development Needs by delivering circa 270 homes that meet local needs including affordable housing and bringing economic benefits to the area including creating construction jobs, generating local spend in the economy and supporting local services. - A resilient and Net Zero Carbon South Warwickshire by contributing towards Net Zero Carbon targets due to its sustainable location with easy access to existing local facilities and services including sustainable transport options with walking, cycling and bus routes all directly accessible from the Site. - A well-designed and beautiful South Warwickshire through the design of buildings, spaces and routes responding to local design codes, where established, and the national objective of achieving well-designed and beautiful places; and protecting and enhancing local heritage and cultural assets by virtue of its location outside of any character areas and distance from protected assets. - A healthy, safe and inclusive South Warwickshire through the design of buildings, spaces and routes and taking the opportunity to establish a new pedestrian and cycle route connecting the existing community at Lillington through the Site and to the Country Park. - A well-connected South Warwickshire by the Site’s proximity to a main bus route and existing pedestrian and cycle routes to enable people to access sustainable and active travel options to connect to centres, jobs, education, cultural facilities, green spaces and the countryside. - A biodiverse and environmentally resilient South Warwickshire by taking opportunities to deliver improvements to environmental assets, and creating a better transitional zone at the urban-rural interface. We consider that the ‘Site’ is suitable, available and achievable meeting the tests in National Planning Policy Framework (NPPF) (July 2021) and also contribute to the five year housing supply as a deliverable site. The Site represents a suitable location for residential development due to its location and proximity to services and facilities. The Site would be adjacent to the established residential area of Lillington, which is a suburb of Royal Leamington Spa. The Settlement Design Analysis indicates that the Site is in a location that fully complies with the 20 minute neighbourhood principle. All the local services and facilities including education, health, convenience retail, open space and places to meet are within walking distance of the Site meeting the day-to-day needs of people. Examples of services include: - Lillington Nursery and Primary School - Lillington Children & Family Centre - Andrew Lee Dental Practice - Mason Avenue Park - Crown Way Shops - Convenience Store, Post Office, Pharmacy, Laundrette, and takeaway restaurants - Lillington Youth Centre The nearest bus stops are located on Buckley Road, 50 metres from the Site, and provide frequent services operating between Cubbington and Royal Leamington Spa Town Centre. The Site’s location on the edge of Royal Leamington Spa places it within the statutory walking distance for both a Secondary School at North Leamington School – a mixed comprehensive school for students aged 11-18 – under 2 km and Royal Leamington Spa College within 3 km of the Site. Warwick Hospital, with A&E services, is within 5 km distance of the Site providing accessible emergency health care. Leisure and recreation facilities can be found at Newbold Comyn where playing pitches, walking and cycling routes are found. The Newbold Comyn Leisure Centre is situated at the entrance to the Country Park. These are within 1 km of the Site. The Site is 2 km from the Town Centre of Royal Leamington Spa where higher order services are found including comparison retail, cafes and restaurants, art gallery and museum, hotels, theatre, gyms and social clubs, cinema and other facilities. Leamington Spa Train Station is 2.5 Km from the Site and can be accessed by bus, walking or cycling routes. The Connectivity Analysis further demonstrates that the Site is accessible. We consider that, based upon a more detailed analysis of the Site’s situation, the current analysis has not appropriately assessed the connectivity grade. The Site is within Area 7 Connectivity Grade: North Leamington and Cubbington. This Area is currently graded as D, however, this assessment has failed to reflect that any barriers to connectivity can be overcome through the creation of a new access, which is feasible and deliverable through working with Warwick District Council. The Site also connects to at least one red route, which is less than 50 metres from the Site and a brown route being within walking distance. There are also existing and potential active links with the current PRoW available connecting to the wider network. There is also the opportunity to create a new route through the Site and link to the Country Park and wider cycle and pedestrian network. The Site should correctly be assessed as a Grade B for connectivity. The Site is not subject to any designations and is in a location that is considered sustainable against the SA Framework. This assessment is set out in the initial Sustainability Appraisal of the Site, below. Sustainability Appraisal The basis of this assessment is the Broad Location, Royal Leamington Spa East, which provides a starting point for the sustainability performance of the Site due to the Site’s location within the Broad Location. SA Objective 1 - Climate Change: Score: '-' Commentary: With the opportunity for circa 270 homes the Site would generate less than 1% increase in carbon emissions in the District resulting in a minor negative impact. There is also significant opportunity to mitigate this impact as the Site supports the 20-minute neighbourhoods principle with the development located close to local services to meet people’s daily needs, reducing the need to travel by private car and encouraging use of active transport and public transport. This would have a positive impact on GHG emissions. GHG emissions can be further reduced through the construction and operation of homes. The incorporation of GI into any future proposals has the potential to retain soils and vegetation in these areas and introduce additional planting that would help to adapt the development to the risks of future climate change. SA Objective 2 - Flood Risk: Score: '+' Commentary: The site is entirely located within Flood Zone 1. SA Objective 3 - Biodiversity and geodiversity: Score: '0' Commentary: The Site does not coincide with any designations. SA Objective 4 - Landscape: Score: '+' Commentary: The site is adjacent to the fringe of the urban area of Lillington. The Options for Future Urban Expansion in Warwick District Considerations for Sustainable Landscape Planning (November 2012) Report concluded, for the Red House Farm site, that this generally flat, greenfield site is situated on high ground south of the Lillington residential estate and... In spite of the topography, it is concluded that a sensitively considered development here could avoid being visually prominent and might have potential landscape benefits e.g. opportunities to make good some urban fringe problems and also to create a better transitional zone at the urban-rural interface. We consider that opportunities exist to improve access to the Countryside and deliver an improved transition from urban to rural bringing minor benefits. There are PRoW that pass through the Site, however, we consider that there are opportunities to deliver benefits. The current PRoW traverses an existing single track used by vehicles with no designated places for passing or pedestrians to use. Through the design of new routes the PRoW can be enhanced for users and their experience improved. SA Objective 5 - Cultural Heritage: Score: '0' Commentary: The Site does not coincide with any designations. SA Objective 6 - Environmental Pollution: Score: '0' Commentary: The Site is not within proximity of any specified receptors. SA Objective 7 - Natural resources: Score: '-' Commentary: The Site is classified as Grade 3 – good to moderate quality agricultural land - under the ALC system. The Site is currently less than 20 hectares of arable fields at the eastern end (about half the site area) and three pony grazing paddocks. The Site also includes previously developed land including the barns and stables used for equestrian activity. SA Objective 8 - Waste: Score: '-' Commentary: The scale of development at circa 270 homes could potentially increase household waste generation by less than 1%. There is the opportunity to also mitigate any impact through provision of appropriate on-site waste and recycling facilities. SA Objective 9 - Housing: Score: '++' Commentary: The Site has the potential to deliver a significant net gain in housing (of 100 dwellings or more). SA Objective 10 - Human Health: Score: '+' Commentary: In addition to the access to GP Surgery, access to Leisure Facilities, the Site not being within or in close proximity to an AQMA or Main Road, access to greenspace (which is a major positive effect on health), access to PRoW / Cycle Path, the Site would be within 5 km distance from a NHS Hospital providing an A&E service. SA Objective 11 - Accessibility: Score: '+' Commentary: The Site is within the target distance of bus stops providing regular services. The Site can also be connected better to the Leamington Spa Train Station through the opportunity for a new route through the Country Park creating potential for shorter walking / cycling distance. We consider that the connectivity analysis has incorrectly assessed the connectivity of the Site, shown by Area 7 Connectivity Grade Analysis: North Leamington and Cubbington. Area 7 is currently graded as D, however, this assessment has failed to reflect that any barriers to connectivity can be overcome through the creation of a new access, the Site connects to at least one red route, which is less than 50 metres from the site and a brown route being within walking distance. There are also existing and potential active links with the current PRoW and opportunity to create new routes through the site linking to the Country Park and wider cycle and pedestrian network. The Site should correctly be assessed as a Grade B for connectivity. SA Objective 12 - Education: Score: '+' Commentary: The Site is within the sustainable target distance of primary, secondary and further education. SA Objective 13 - Economy: Score: '+' Commentary: The Site comprises undeveloped land with the exception of those used for equestrian facilities. The equestrian facilities will be relocated so that the employment generated will be retained. The Site is located within the target distance to various employment opportunities. The Site is considered available for development demonstrated by this submission and response to the Call for Sites. The Site is in single ownership, and the landowner has expressed intention to sell, with a land promoter appointed demonstrating that it is available for development now. Residential development on the Site is achievable as there are no known impediments to development and no foreseen extraordinary development costs or constraints that would impact on the economic viability of the Site. Market conditions are considered favourable and the HEDNA identifies that future demand for new homes is driven by population growth and job creation. The Site is also considered to be deliverable, as it is available now, offers a suitable location for development now, and there is a realistic prospect that housing will be delivered on the site within five years. The Site can make a positive contribution to meeting housing needs early in the Plan period with potential to accommodate circa 270 homes. The Site’s suitability, availability and achievability for residential development is further detailed in the following assessment applying the methodology of the Coventry and Warwickshire Sub-Regional Joint Method Statement Housing and Economic Land Availability Assessment - (February 2022). SUITABILITY Site/Location Attributes | Assessment - Green | Commentary - The site is 13.4 ha Site Purpose | Assessment - Green | Commentary - The site has been put forward for residential development Site Location | Assessment - Green | The site is within or immediately adjacent to an existing settlement, that settlement being a main urban area - Royal Leamington Spa. National Policy Designations - Green Belt | Assessment - Amber | Commentary - The site is wholly or substantially within the designated green belt. Sites which fully or partially fall within the Green Belt will not be automatically removed from the assessment process and will need to be assessed as part of the overall development strategy of the SWLP. The Site aligns with the emerging vision, objectives and spatial strategy and would constitute a sustainable pattern of development. There are considered to be exceptional circumstances to support Green Belt review and allocation of the Site. National Policy Designations - AONB | Assessment - Green | The site is wholly outside of the designated AONB and not adjacent to it. National Policy Designations - Registered Parks and Gardens | Assessment - Green | The site is not within or adjacent to a registered park or garden. Ecological designations | Assessment - Green | The site does not include any land within the following designations European Wildlife site, National Wildlife Site, SSSI, Special Protection Area (SPA), Local Wildlife Site, Potential Wildlife Site, Ancient Woodland. Land Constraints - Flood Risk | Assessment - Green | The site is wholly outside of flood zones 2 and 3, and where surface water flooding exists mitigation and adaption are available. Land Constraints - Brownfield/ Greenfield | Assessment - Amber | The site is substantially comprised of land that has not been previously developed (greenfield) however the equestrian facilities including the house, stables, arena and hardstanding would constitute previously developed land. Agricultural land quality | Assessment - Green/Amber | The site comprises grade 3 land, further assessment required to determine the sub category. Land constraints - Minerals and waste | Assessment - Green | The site is not within a minerals and waste allocation or safeguarded area, as defined on the Warwickshire Published Mineral Resource Map. Heritage Constraints | Assessment - Green | The site does not include any designated heritage assets, and it is unlikely to directly impact upon the setting of any heritage assets. AVAILABILITY Ownership | Assessment - Green | Site is in single ownership, and the landowner has expressed intention to sell, and a land promoter appointed. ACHIEVABILITY Viability and deliverability | Assessment - Green | No foreseen extraordinary development costs or constraints. Market conditions appear favourable. Green Belt and Exceptional Circumstances The Site is covered by the West Midlands Green Belt. In line with the NPPF there are considered to be exceptional circumstances that can be fully evidenced and justified for a review of the Green Belt boundary and allocation of the land at Red House Farm for residential development. The publication of the South Warwickshire Local Plan: Urban Capacity Study (October 2022) and the Local Plan Issues and Options Consultation Document demonstrate that the strategic policy-making authorities have examined fully all other reasonable options for meeting identified needs for development and that releasing land from the Green Belt is justified and would promote sustainable patterns of development. We consider that there are exceptional circumstances to justify changes to the Green Belt boundaries and release of the Site and its allocation for residential development. The exceptional circumstances include: Reason 1 - sustainable patterns of development The NPPF establishes that when drawing up or reviewing Green Belt boundaries the need to promote sustainable patterns of development should be taken into account. This is further recognised in the Local Plan and evidenced by the SHEELA, Sustainability Appraisal and Settlement Design Analysis. The Site forms a natural extension to the main settlement of Royal Leamington Spa being adjacent to the established residential area of Lillington, which is a suburb of the main urban area. The Settlement Design Analysis indicates that the Site is in a location that fully complies with the 20 minute neighbourhood principle. Residential development at the Site would constitute a sustainable pattern of development in a location that is well connected with good infrastructure and access to facilities and services. The Site performs positively against the Plan’s Sustainability Appraisal Framework and the methodology of the Coventry and Warwickshire Sub-Regional Joint Method Statement Housing and Economic Land Availability Assessment. This is demonstrated earlier in this Appendix. The available evidence demonstrates that the Site is suitable, available and achievable. There are no significant constraints to residential development and where they do exist these can be mitigated. The Site’s development for residential use aligns with the vision and strategic objectives of the Plan and would promote a sustainable pattern of development. The Site would also deliver a range of economic, social and environmental benefits contributing to achieving sustainable development. These benefits are set out in Appendix 4 and include: - A sustainable place - extending the existing community of Lillington with a new sustainable residential development that has access to all the services and facilities to meet the day to day needs of future residents along with transport options to connect to health, education, jobs and leisure. - Housing - provide circa 270 homes including affordable housing. The range of homes will increase choice in the local area meeting housing needs including for smaller properties and family housing. - Improved connections - promote sustainable transport choices where walking, cycling and public transport are all viable options. A new strategic link between Lillington and Newbold Comyn can be established facilitating pedestrian and cycle movement. It would bring the community at Lillington closer to the services and amenities at the Country Park and Royal Leamington Spa Town Centre. - New access to the country park - bringing health and wellbeing benefits to residents a new access to the Country Park could be established. Current and future residents would have a new direct access to the amenities for sport, recreation and leisure. - Health and wellbeing - providing a variety of new open spaces for recreational space. - Improved urban rural transition - preserving and enhancing the important aspects of the existing landscape and providing a softer transition with new landscaping. - Biodiversity benefits - integrating existing habitats into a comprehensive landscape scheme with added new wildlife habitats and green corridors. - Relocation of existing equestrian facility - the existing equestrian facility including the livery stables relocated to alternative premises retaining local jobs and facilities. - Permanent Green Belt boundary - establish a new permanent boundary for the Green Belt utilising mature trees and hedgerows and the conversion of the existing buildings. Reason 2 - housing land capacity to meet housing need The Local Plan has demonstrated that all other reasonable options for meeting the development needs have been explored, including the use of brownfield land, optimising density and engaging with neighbouring authorities about accommodating any development needs. The South Warwickshire Local Plan: Urban Capacity Study (October 2022) evidences this position and demonstrates the significant challenge for the area in meeting local housing needs within existing settlements and on brownfield land. Factoring all of the sources of potential urban and existing committed housing capacity the study shows a total potential baseline housing supply for the 2025-2050 Plan period of 19,950 dwellings. The study also considers options for higher densities, which would require a higher burden of evidence in order to ultimately demonstrate this is deliverable, and building on car parks which would require significant levels of intervention and management to release. The available capacity compares to a housing need for South Warwickshire over the new Plan period of 30,750. This housing need is derived from the Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA) (November 2022). The assessment of housing land supply vs demand uses the new trend-based projections for Warwick and Stratford-on-Avon resulting in a need for 1,239 dwellings annually. If the Standard Method was applied the figure would be 1,679 per annum or 41,975 over the plan period. The Study concludes that it is impossible to meet development needs without significant greenfield development. This conclusion is based upon the lower housing need figure and excludes meeting a proportion of the unmet need from neighbouring areas, including Greater Birmingham and Coventry. The Site can make an important contribution to meeting housing need with circa 270 homes. These homes can be delivered early in the Plan period. Reason 3 - contributing to improving health and wellbeing The area of Lillington, is in the top 20 percent of the country’s most deprived areas (Lillington East), according to the Index of Multiple Deprivation. The Lillington Regeneration Needs Assessment (2016) has identified a series of health and wellbeing needs of the population of Lillington and recommendations for improvements. The Site can make a significant contribution to the Strategic Objectives of the Plan; namely to deliver a healthy, safe and inclusive; and a well-connected South Warwickshire by providing new pedestrian and cycle routes that would create a direct connection from Lillington to the Newbold Comyn country park. A new entrance point to the Country Park would open up access to the leisure and recreation facilities for the wider community leading to improved health and wellbeing opportunities for residents. The Site can also facilitate access to the national cycle network. In light of the above, it is therefore considered that there are exceptional circumstances which can justify changes to Green Belt boundaries. The release of the Site from the Green Belt would facilitate sensibly planned growth and direct development away from the most sensitive areas of the Green Belt. This is considered further below. Purposes of the Green Belt The Site is covered by the West Midlands Green Belt. The NPPF ‘Protecting Green Belt Land’ is clear that where development is unavoidable it should be directed away from the most sensitive areas of Green Belt. Sites which therefore do not make a strong contribution to the role and function of the Green Belt will be considered for potential release in order to facilitate sensibly planned growth. To check the unrestricted sprawl of large built-up areas The Site is located on the southern edge of Lillington, and is bounded to the west by water treatment works. There are mature trees and hedgerows, with some veteran trees, and existing buildings including a house and equestrian facilities (brownfield land) forming the southern boundary of the Site. Given the assessment in Options for Future Urban Expansion in Warwick District Considerations for Sustainable Landscape Planning (2012) the Site has an urban fringe character. If it were removed from the Green Belt, the Site would therefore form a logical extension to the urban area being bounded by built form to the west and residential to the north. The retention of existing mature trees and hedgerows and provision of a landscape transition would create a contained development and checking any unrestricted sprawl. Development would ‘round-off’ the existing urban area in this location and provide a softening of the existing transition from urban to rural. To prevent neighbouring towns merging into one another The Site is located in an urban fringe location, at the current built up edge of Lillington, a suburb of the main settlement of Royal Leamington Spa. The nearest settlements are Cubbington, Radford Semele, and Offchurch. Cubbington is to the north east and the Site is directed away from the Site’s location, there is no role in preventing merging. Both Radford Semele and Offchurch are over 2 km from the Site and are separated by significant change in topography and landscape character. There is no risk of merging. The development of the Site would therefore not worsen the existing position with regard to the ‘merging’ of neighbouring towns, as, although it would constitute the expansion of development beyond existing boundaries, it would not encroach on neighbouring settlements due to the distances, existing physical features in the landscape and changes in topography. To assist in safeguarding the countryside from encroachment Most Green Belt sites will make a contribution to openness, but the Site, as previously explained due to topography and location, means it can make a potential positive contribution to the wider landscape. The Site would be viewed as a natural extension of the existing urban area and be viewed as ‘rounding off’ the existing settlement. It is proposed to retain key landscape features of the Site including significant internal hedgerows and field trees. The development will also work with the natural topography of the Site. Opportunities also exist to provide mitigation planting and ecological enhancements in line with the Site’s landscape character. To the southern boundary of the Site are the existing equestrian facilities with a house, stables, large shed structure and arena / hardstanding constituting previously developed land. To preserve the setting and special character of historic towns The Site is on the edge of Lillington, a predominately 1950s suburban area which includes four-storey flats adjacent the Site at Mason Avenue / Burberry Close, and although not immediately adjoining, the much taller Eden Court and Southern Court flats. There are no heritage designations within the Site itself, or in proximity. As such, heritage sensitivities are fairly limited at the Site and development of the Site could not be said to undermine the setting and special character of a historic town. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land The removal of this Site from the Green Belt would not affect urban regeneration through the recycling of derelict and other land. Given the growth needs for the area and the acknowledgement of the unmet need for housing, it is clear that greenfield and Green Belt land must be released to meet housing numbers if sustainable patterns of development are to be achieved. Overall the amendment to the Green Belt would allow for a sustainable pattern of development to be achieved and would not undermine the purposes of the Green Belt designation across the wider area. Appendix 4 - Red House Farm Development Framework [SEE ATTACHMENT]

Q-S7.2 - Response: Whilst we understand the reasoning behind removing the Green Belt in consideration of the holistic growth options at this stage, it makes it difficult to identify a specific strategy that will be appropriate from the options presented. Green Belt is not a neutral factor and will play an important role in the eventual consideration and choice of sites for allocation in the Local Plan. In this regard, a strategy which seeks to ensure that the right sites, in the right location, are identified for sustainable growth will have to consider Green Belt constraints. Sites which can deliver economic, social and environmental benefits without impinging on the Green Belt should be prioritised for allocation. Notwithstanding, of the options presented, a hybrid, synergising options 1-4 would, at this stage, seem the most logical approach. Option 5 (dispersed growth) does not appear sustainable as it disperses development too greatly across South Warwickshire, which would not encourage sustainable travel, as noted in the supporting text. Land at Red House Farm provides the opportunity to deliver significant, mixed employment development, with the associated benefit of a new motorway junction in a well connected location which, significantly and importantly, is outside of the Green Belt. Q-S10 - Response: It is important that the final growth option taken forward does not constrain economic growth, which (particularly in the logistics and warehouse sector) is greatly driven by market demand and accessibility to the Strategic Road Network. In this context, it is also important that there is a clear distinction drawn between considering sites for housing growth and employment schemes. Whilst connectivity is important for both housing and employment sites, the fundamentals of these connections are different. Housing schemes need to be well related to places where people will work and play. However, for employment schemes there is the added requirement of strategic connections to the markets they serve; this can be regionally, nationally and internationally.

Q-S8.1 – Settlements falling outside the chosen growth strategy: A threshold approach to small scale development is inappropriate in greenbelt areas, nor should the plan allow for more small-scale growth developments to come forward in greenbelt areas.

I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. As mentioned above, this is a fallacious argument, because preservation of the greenbelt contributes positively to reducing the impacts of climate change. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries, especially when this can be used as a means of permitting development in what would have otherwise been greenbelt . This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population. Given the very small number of respondents, is it possible that these were from developers or others who would benefit from such development, as I note that there were almost as many sites submitted as responses received? The tiny number of respondents should therefore not be used as a basis for decision making and should not be used to justify development or a review of the greenbelt.

Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Q-S3.2 Please select the option which is most appropriate for South Warwickshire Option S3.2c: None of these 2.6 St Philips considers that the SWAs priority should be to direct development to the most sustainable locations. St Philips recognises that the NPPF places emphasis on the need to make as much use of brownfield land as possible, with paragraph 119 stating that: “Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.” 2.7 Paragraph 120 of the NPPF continues by stating that “Planning policies and decisions should: • give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land; and • promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively.” 2.8 However, it should be noted that whilst the use of brownfield sites is emphasised, there is a need to consider the NPPF as a whole. Paragraph 11a of the NPPF is clear that “all plans should promote a sustainable pattern of development”. In this regard, whilst suitable brownfield sites will often naturally emerge as sustainable locations for development, it is possible for greenfield land to provide a more sustainable location for development than unsuitable brownfield land. 2.9 St Philips also notes that the SWLP ‘Urban Capacity Study (October 2022)’ has established that South Warwickshire is unlikely to be able to meet its development needs solely through the use of previously developed land.1 Therefore, regardless of the approach taken by the SWLP, there will still be a need to identify significant amounts of suitable greenfield land for development. 2.10 In this context, St Philips believes the Councils approach should emphasise sustainability, rather than arbitrarily prioritising brownfield sites over more sustainable greenfield locations. St Philips would therefore support the effective reuse of brownfield land alongside the release of greenfield land in sustainable locations as directed by the Settlement Hierarchy or through the delivery of a new settlement (subject to consideration of the delivery of core facilities and accessibility). Q-S5.2 Do you think new settlements should be part of the overall strategy? Yes. As stated, the NPPF is clear that the supply of large numbers of new homes can often be best achieved through planning for larger-scale developments (Para 73). Importantly, it is also clear that plans should be prepared positively, in a way that is aspirational but deliverable (Para 16b), and should identify specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan (Para 68b). However, for a plan to be found ‘sound’, it must set out an appropriate strategy, taking account of reasonable alternatives, and be based on proportionate evidence (Para 35b). 2.16 In this regard, it is also important to note that the NPPF shifts the need to consider viability to the plan-making stage, requiring authorities to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability (Para 68). 2.17 The Planning Practice Guidance [PPG] provides further clarity for new settlements, stating that LPAs should demonstrate that there is a reasonable prospect that large scale developments can come forward. In particular, this should include a realistic assessment about the prospect of sites being developed and should engage with infrastructure providers to ensure that the infrastructure requirements are not beyond what could reasonably be considered to be achievable within the planned timescales. 2.18 St Philips therefore does not consider that new settlements are the panacea for housing delivery. Whilst the proposed SWLP plan period would extend up to 2050, and conceivably enable sufficient time for a new settlement to fully deliver, there are still legitimate issues regarding this type of housing delivery and the evidence required to successfully underpin a proposed allocation – notwithstanding that SOADC secured the allocation of Long Marston Airfield. In this regard, St Philips welcomes the IOs recognition that whilst new settlements can be an effective way of delivering housing growth, further detailed assessment of the identified potential new settlement locations is required. The IO rightly acknowledges that “there is the possibility once these detailed assessments have taken place and in light of any comments received to the Issues and Options consultation, none of the potential locations are deemed suitable” (IO, page 49). 2.19 It is particularly important that, where new settlements are intended to be a large proportion of areas housing needs, there should be a robust – and proportionate – evidence base demonstrating that the site is deliverable. In the absence of this, there is a very real risk that a Local Plan could be found ‘unsound’ at examination. 2.20 Indeed, the examination of the North Essex Authorities’ [NEA] Section 1 Local Plan highlights the above issues. In particular, to meet housing needs over the 2013-2033 plan period, it proposed the allocation of three garden communities. However, the Inspector concluded that two of these proposed settlements should be deleted in order for the plan to proceed as they weren’t deliverable, on viability and infrastructure grounds. 2.21 Furthermore, at the examination of Hart District Council’s ‘Hart Local Plan (Strategy and Sites) 2032’, the Inspector’s concern was that the new settlement was being advanced as a long-term solution, but no alternatives to that option had been considered or properly tested in preparing the plan. The Inspector also noted that “there is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership” [IR63]. 2.22 In any event, the NPPF is clear that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed” (Para 60). As discussed, the NPPF emphasizes the importance of small-medium sites, stating that small and medium-sized sites can make an important contribution to meeting the housing requirements of an area, and are built out relatively quickly (Para 69). In this context, notwithstanding St Philips position on issues associated with pursuing New Settlements, the SWLP will need to allocate a variety of small-medium sized sites to deliver housing in the first 5-15 years of the plan period. Q-S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 2.23 The IO sets out five spatial Growth Options, comprising: a Option 1: Rail Corridors b Option 2: Sustainable Travel c Option 3: Economy d Option 4: Sustainable Travel and Economy e Option 5: Dispersed 2.24 For each growth option an indicative list of settlements is provided. It is noted that many locations feature in more than one option. In this regard, St Philips is promoting land on the edge of Studley for residential development. In the context of St Philip’s site, it is noted that Studley is identified as a potential location in Growth Options 2 (Sustainable Travel), Option 4 (Sustainable Travel and Economy) and Option 5 (Dispersed). St Philips welcomes the inclusion of Studley in several Growth Options. 2.25 Some of the proposed spatial growth options have been brought forward from the Scoping Consultation, whilst others are hybrids of the previous options. St Philips considers that the current options should, in theory, allow the Issues and Options Consultation to consider how South Warwickshire could accommodate housing growth to meet its own housing needs, and a proportion of the C&WHMA and GBBHCMA’s unmet housing needs. 2.26 Nevertheless, St Philips considers that a mixed growth strategy, which combines several growth options, will prove to be the best growth strategy for South Warwickshire. In this regard, St Philips notes that the SA evaluates the 5 spatial growth options and concludes the following: South Warwickshire Local Plan: Regulation 18 Issues and Options Consultation : Representations on Behalf of St Philips Pg 8 “An overall best performing option is hard to identify. Option 5 is the worst performing option whilst Option 2 is likely to align most closely with development that will ultimately seek the most effective mitigation against climate change” (Para 7.15.2). 2.27 The SA goes on to acknowledge that different options perform better for certain SA objectives than others. St Philips also notes that the SA does not consider the potential for mitigation when evaluating the growth options, and that the scores are “strictly a guide and do not represent a diagnostic analysis” (Para 7.15.1). St Philips therefore considers that the SA is inconclusive regarding which of the growth options performs best. In this context, St Philips believes that the spatial strategy should not entail one particular growth option. It is considered that the five growth options interconnect, and in order to achieve the development needs within and beyond South Warwickshire up until 2050 a mixed strategy should be adopted. This would ensure a flexible and robust approach that would disperse the benefits of growth between all settlements within the South Warwickshire. 2.28 Regardless of which growth strategy the Council pursues, St Philips considers that some development will likely need to be dispersed to ensure that the entirety of South Warwickshire benefits from housing growth. This is acknowledged within the ‘Evolving the Spatial Growth Options Topic Paper August 2022’ which sets out how the 7 high level spatial growth options presented in the Scoping Consultation evolved into the 5 options presented within the IO. The Topic Paper acknowledges in relation to option 5 (Dispersed) that “even if this option were not taken forward, some limited growth might still need to occur in some smaller settlements to support the overall sustainability of these places” (Appendix 2). Therefore, although Option 5 does not perform comparatively well within the SA and Estimation of Emissions Study, St Philips considers that it will be necessary to disperse some growth to support the sustainability of smaller settlements. 2.29 On this basis, St Philips considers that a mix of the Growth Options will promote sustainable patterns of development across South Warwickshire and aligns with the sustainability aspirations that are set out in the NPPF. Whilst greater levels of development may need to be focussed around sustainable transport corridors, due to the level of infrastructure and services already present, it will also be necessary to direct growth to other settlements to ensure that the benefits of housing growth can be delivered in other parts of South Warwickshire. In particular, St Philips consider that there are several benefits to a mixed approach to the distribution of development: 1 It would support the well-being of those settlements that have the capacity to accommodate growth; 2 By concentrating development around existing and proposed new infrastructure it would also ensure that it benefits from a sustainable location with good access. Such an approach would allow the Council to capitalise on opportunities presented by existing or planned infrastructure when considering options for large scale new residential developments, in accordance with paragraph 73a of the NPPF; 3 When having regard to the need to release Green Belt land, such an approach would also be consistent paragraphs 141 and 142 of the NPPF: Where amendments to Green Belt boundaries are required, the promotion of sustainable patterns of development should be considered, alongside giving first consideration to land which is (inter alia) well-served by public transport (Para 142); South Warwickshire Local Plan: Regulation 18 Issues and Options Consultation : Representations on Behalf of St Philips Pg 9 4 It can ensure that a sufficient supply of homes, within close proximity to existing and future employment opportunities, contributes to an efficiently functioning economy. This can also aid in minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions); and 5 It would enable growth to meet the needs of neighbouring authorities to be located in an area close in proximity to where these needs arise. Similar to the above, this also has the added benefit of minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions). Land at Brickyard Lane, Studley 2.30 As set out in Section 1.0 of these representations, St Philips is promoting Land at Brickyard Lane, Studley for residential development. The site, encompassing an area of c.1.78 ha, is formed of a singular field of grassland which fronts the A448 and Brickyard Lane and is enclosed to the east and west by residential housing and the Renshaw Industrial Estate. The site is well contained with established vegetation along the site boundaries and a category A tree situated to the north-west corner of the site. It is rectangular in shape and generally flat. 2.31 The Site is situated on the western edge of Studley, in the Green Belt. Studley is located approximately 12 miles north-west of Stratford-upon- Avon, 5 miles south of Redditch and 20 miles south of Birmingham. A regular bus service also runs through the village providing connections to Studley and Redditch. Redditch Railway Station provides regular train services into Birmingham New Street. 2.32 The land has previously been promoted through the Call for Sites process, culminating in its inclusion within the 2018 and 2020 Strategic Housing Land Availability Assessments [SHLAA] (Site Ref: STUD.22). Both SHLAAs concluded that the Site overall was ‘amber’, or ‘likely to be deliverable’. In essence, there are no known constraints on the site that would preclude development, subject to appropriate mitigation measures being put in place where required. However, the Site was excluded from the Council’s process as it fell within the Green Belt. 2.33 St Philips wishes to reaffirm the site’s status as being ‘suitable, available and achievable’. The Site could provide approximately 1.3 ha of residential development, equating to approximately 50 new homes. The Vision Document, submitted in support of these representations, demonstrates that the Site could deliver a residential development in a sustainable location. The Site is surrounded by strong defensible boundaries, including existing dwellings to the east and west, and has an enclosed landscape setting. 2.34 St Philips consider that the Site presents an excellent location to deliver up to 50 dwellings, including up to 18 affordable dwellings. The scheme would be responsive to its surroundings, including through the protection and enhancement of the strong Green Infrastructure network. Connectivity through the Site and to the village and surroundings would be emphasised to encourage sustainable travel.