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

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-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? I think that a proportion of future growth should be attributed to existing non-Green Belt settlements, and primarily to towns across South Warwickshire since these include a wide range of services and facilities required to sustain growth. This approach will allow for development to be delivered in the early years of the plan period. I note that the Levelling-up and Regeneration Bill: reforms to national planning policy seek to strengthen Green Belt policy. The NPPF proposes that ’Green Belt boundaries are not required to be reviewed and altered if this would be the only means of meeting objectively assessed needs for housing over the plan period.’ A preferred option for future growth should therefore be focused on sites outside of the Green Belt. Q-S5.2: Do you think new settlements should be part of the overall strategy? 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? Q-S5.4: If not, what approach would you take? I support the proposition of a new settlement provided that it is located in the most appropriate location. Bus services, alongside rail services are equally important in providing active travel options in response to the climate change emergency, and should form part of the preferred approach to identifying potential locations. This approach will reduce the need to travel by car. The assessment of potential location C1 (Kingswood) in Table 6 is misleading in respect of its access to the strategic road network since junction 16 of the M40 offers westbound access to the M42 only. The assessment of potential location C1 should be amended to accurately reflect this limitation, which has significant implications for the appropriateness of the settlement for housing (and employment) uses.

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-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.

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-S3.2: Brownfield land Approach Option 3.2a: Prioritising 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 that the priority is to make effective use of land in meeting objectively assessed needs and that that this should make as much use as possible of previously developed or brownfield land. However, in stating this, it is also clear that the NPPF does not seek the use of brownfield land ahead of all other considerations and instead points to a balance when there is potential for conflict with other policies in the Framework. Brownfield land for development needs to be on the right sites, in the right location and as the Plan rightly indicates, locating development on brownfield land but in unsustainable locations can cause/or exacerbate issues in an area. In view of this, the balanced approach stated in Option S3.2a is considered the most appropriate. It is clear from the HELAA and level of growth that is needed across the plan area that a significant quantum of greenfield land will be required to accommodate development needs, such as land controlled by CEG and Mixed Farms. This is further evidenced through the Council’s Urban Capacity Study 2022, which confirms that capacity through urban sites and existing commitments is 19,950 dwellings over the plan period, leaving more than 10,000 dwellings to be accommodated on greenfield sites beyond the urban area.

Q-S3.2: Brownfield land Approach Response- Option 3.2a: Prioritising 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: 3.1 Paragraph 119 of the NPPF is clear that that the priority is to make effective use of land in meeting objectively assessed needs and that that this should make as much use as possible of previously developed or brownfield land. However, in stating this, it is also clear that the NPPF does not seek the use of brownfield land ahead of all other considerations and instead points to a balance when there is potential for conflict with other policies in the Framework. Brownfield land for development needs to be on the right sites, in the right location and as the Plan rightly indicates, locating development on brownfield land but in unsustainable locations can cause/or exacerbate issues in an area. 3.2 In view of this, the balanced approach stated in Option S3.2a is considered the most appropriate. In any event, it is clear from the HELAA and level of growth that is needed across the plan area that a significant quantum of greenfield land will be required to accommodate the development needs, such as land controlled by CEG. This is further evidenced through the Council’s Urban Capacity Study 2022, which confirms that capacity through urban sites and existing commitments is 19,950 dwellings over the plan period, leaving more than 10,000 dwellings to be accommodated on greenfield sites beyond the urban area. Issue S4: Growth of existing settlements Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.3 It is considered that growth of some of the existing settlement should feature as part of the overall strategy as this will help to ensure a sustainable pattern of development through aligning growth with jobs, services and facilities and infrastructure provision. Land to the South of Coventry should be included within this process. 3.4 Whilst outside of South Warwickshire, the City of Coventry, as the sub-regional centre, should be acknowledged as part of the overall strategy as indeed was the case in the formulation of the Warwick District Local Plan. Land to the South of Coventry at Westwood Heath should therefore be considered for growth for a residential led mixeduse development as part of the overall strategy within the SWLP.

Issue S4: Growth of existing settlements Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 2.11 It is considered that growth of some of the existing settlements should feature as part of the overall strategy as this will help to ensure a sustainable pattern of development through aligning growth with jobs, services and facilities and infrastructure provision. As noted in response to QI-1, Gaydon/Lighthorne Heath is a Main Rural Settlement that is well placed to contribute towards this pattern of development. 2.12 Specifically regarding Gaydon/Lighthorne Heath, this is a 3,000 home new settlement allocated in the Stratford Core Strategy. The development features a range of services, facilities and green infrastructure including; • a village centre with a range of shops and services to support the development itself and the wider area. • A community hub to include meeting space, health, police office and leisure facilities • A three-form entry primary school • A network of green infrastructure 2.13 The site is now delivering a significant number of housing completions and the community is quickly becoming established. Indeed, completions are taking place at a pace beyond that envisaged within the Core Strategy, which assumed 150 dwellings per annum at 2021/22 and over 250 homes are now occupied. 2.14 The Core Strategy recognises the sustainability and significance of Gaydon/Lighthorne Heath through the supporting text to policy CS.15 which confirms that it will become the equivalent of a Main Rural Centre and complement their role. 2.15 As a consequence of the sustainability and role of Gaydon/Lighthorne Heath, this Site, which is currently within the GLH extant allocation but safeguarded for Jaguar Land Rover, should therefore be considered for growth for a mixture of uses as part of the overall strategy within the SWLP. Further justification for this is provided in the answers to questions S7.2 and E7.2.

Any other comment: You cannot use the Climate Emergency as an argument, this is such a strange argument as by building these developments common-sense tells you that you are directly impacting the environment that leads to climate change. It is so damaging to the environment by building on greenbelt land.

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. Issue B1: Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

Issue S2: Intensification: There are compelling reasons to have strong policies to support increasing active travel (cycling and walking), maintaining and improving public transport and local services and reducing the need to build on greenfield sites. 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.

There needs to be a compelling reason to build on greenbelt in my view. Purely supplying houses to meet demand doesn’t dampen the demand, else areas such as Milton Keynes with massive year on years building would have run out of those needing houses by now. Wildlife and farmers need the 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-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. 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. 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.

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.

Issue S2: Intensification: There are compelling reasons to have strong policies to support increasing active travel (cycling and walking), maintaining and improving public transport and local services and reducing the need to build on greenfield sites. 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. If you have any further comments, please write them here: A bigger percentage of social housing should be allocated to Kenilworth born families so they can afford to stay in the town as a priority over other people moving into the town.

Executive Summary Land to the south of Broad Lane, Aspley Heath, Tanworth in Arden, B94 5HR. The land which is circa 6.11ha currently sits within the West Midlands Green Belt however the land does not contribute to the five purposes of green belt land. The site sits in the middle of a quadrangle of development depicting a very urban form, please refer to the os plan attached. The land is located in a sustainable location close to excellent transport nodes and the development of this land would not impact on the interests of acknowledged importance. The land is grade 4 agricultural land with no real constraints to development. The development of this land would not contribute to urban sprawl as the land offers the opportunity for "infill" residential development along with community facilities and therefore would not impact on the greater green belt area. Indeed it would complement the existing settlement form and pattern. In essence the development of this land would contribute to the vision and strategic objectives of the South Warwickshire Local Plan by providing for a climate resilient net carbon zero development for a mix of well designed houses and bungalows, providing a healthy, safe and inclusive twenty minute neighbourhood. It offers good connectivity coupled with the opportunity for an enhanced and managed biodiverse resilient proposal. Description The land is located within the settlement of Aspley Heath, which forms part of the parish of Tanworth in Arden, Warwickshire, close to the A435 Alcester to Birmingham Road. The site amounts to some 6.11ha. (15.107acres) or thereabouts. The land is predominately laid down to pasture, sub-divided into three fields by mature hedgerows/tree belts, and an area of woodland. The site sits at about 165m AOD and gently undulates. The north-western boundary provides frontage onto the B4101 Broad Lane. The north-eastern boundary is formed by the back gardens of residential properties fronting onto Arden Leys, off Aspley Heath Lane. The eastern, south-eastern and south-western boundaries are formed by back gardens and paddocks of residential properties fronting onto Aspley Heath Lane and Blind Lane. The principal agricultural access to the land is currently off Broad Lane, with a further access off Arden Leys. A public bridleway runs between Aspley Heath Lane and Blind Lane along the woodland strip forming the south-eastern boundary of the site. The site is well located for connection to various and significant transport nodes. A regular bus service between Moseley and Alcester, Solihull and Redditch stops on Broad lane close to the subject land. Wood End station which provides a regular service to Birmingham and Stratford upon Avon is within a 10-15 minute walk circa 4 mins for cyclists. Junction 3 of the M42 motorway is approximately 2.3miles distant. A primary school is located within Tanworth in Arden village, along with a church, tennis and bowling club. The area is well catered for with two local public houses namely the Warwickshire Lad and The Bell. Ladbrooke Park Golf Club provides further recreational facilities on the doorstep. Under Issue S6 of the Consultation Document The land at Broad Lane offers probably the best opportunity available within the region " to focus on development sites which provide limited harm to the greenbelt". The Five Purposes of Greenbelt land. to check the unrestricted sprawl of large built-up areas; to prevent neighbouring towns merging into one another: to assist in safeguarding the countryside from encroachment; to preserve the setting and special character of historic towns and to assist in urban regeneration by encouraging the recycling of derelict and other urban land. The subject land does not significantly contribute to any of the above five purposes. The land is developed on all sides and therefore it restricts any further growth which would result in "unrestricted sprawl" the existing development provides a ready defensible boundary against any further development. In light of the above there is no risk of coalescence with any other town or village as any proposed development is constrained to within the broadly rectangular format provided by the current urban form. The land is of limited value in terms of landscaping it does not provide a traditional setting depicting a typical rural environment, quite the contrary the land is surrounded by development it therefore cannot be defined as open countryside. The land does not contribute to preserving the setting of any special character. It is not within a conservation area nor are there any listed buildings of historic or architectural importance within the sphere of influence. Heritage is therefore not an issue. Indeed the surrounding development is primarily a mix of unimaginative houses from the 60,s 70s and 80s many of which have been overly extended with an array of hideous annexes and bland conservatories coupled with an interesting variety of large garden sheds, offices, gyms and garden rooms, it's overlying characteristic form is undeniably urban. Both interestingly and timely, The Royal Town Planning Institute on behalf of its members has responded on the National Planning Policy Framework (NPPF)consultation dated 2nd March 2023 and comments as follows; 'We believe that proportionate reviews of Green Belts at a strategic (i.e. city-regional) level are important for them to serve their intended purpose as a policy tool for preventing urban sprawl. The reviews must be flexible to react to changing needs and settlement patterns as well as accommodating high-quality development." Sustainability National Planning Policy Framework sets out three overarching objectives in achieving sustainable development; environmental, economic and social. The site performs well in relation to these aspects as detailed below. Economic Objective Development should be consistent with the aim of building a strong, responsive and competitive economy by ensuring sufficient land of the right type is available in the right places and at the right time to support growth. The site identified at Aspley Heath could deliver a mix of residential dwellings which has good access to a wider functional economy. Indeed the site is well located in terms of the "twenty minute neighbourhood" as it is within easy walking distance to bus stops; train station, public house and doctors surgery. Social Objective Sustainability should support strong, vibrant and healthy communities and accessible services by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations. The provision of a mix of residential dwellings will help maintain the existing community, but also in allowing sufficient flexibility to satisfactorily address the social objectives of the NPPF. Environmental Objective The NPPF establishes a requirement to protect and enhance the natural built and historic environment. The site at Aspley Heath although it lies within the greenbelt it provides little in the way of the five purposes as previously stated. Indeed the land is encompassed by residential development on all sides which provides an urban feel rather than one of "open countryside " with which one usually associates with greenbelt land. It is a remarkable example of land which contrasts with the usual characteristics of greenbelt land. It is not located within a conservation area nor is it located close to any listed buildings. It is not located within an area of flood risk (zones 2 or 3) Its landscape is diluted by the surrounding residential properties and their urban form. The land agricultural value is low "grade 4" and provides a small amount of grazing. Thus the loss of such land will be of little consequence. In bringing the site forward for development any proposal will make efficient use of available land to deliver a mix of well designed houses and bungalows providing a much needed mix of tenures in this location. A proposed scheme providing for woodland management and additional planting coupled with a wildflower meadow will support a substantial gain in biodiversity terms. Sensitively designed and well located residential development of appropriate size and scale would not erode the character and appearance of the surrounding area and would not have an adverse impact on local accessible open space. Given the location of the submitted site, proposals for residential use at the site would complement the existing settlement form and pattern and provide what is in fact "infill development". Conclusion This parcel of land does not contribute substantially towards any of the acknowledged greenbelt purposes. It is clear that over the years the area of Aspley Heath has changed and there is now an opportunity to flex on the changing needs of settlement patterns as it offers an opportunity to embrace a development of high quality net carbon zero housing within a sustainable location. The development of this land will not contribute to "urban sprawl" it is an infill opportunity in an area which would benefit from having a mix of housing to satisfy local needs. The land is available, deliverable and subject to being released from the greenbelt achievable. In essence the development of this land would contribute to the vision and strategic objectives of the South Warwickshire Local Plan, namely; Climate resilient with a net zero development; well designed; providing a healthy, safe and inclusive opportunity with good connectivity which provides an enhanced and managed biodiverse and environmentally resilient proposal in South Warwickshire.

Issue B1: Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

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-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-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. 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. 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.

Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

Q-S1: Please select the option which is most appropriate for South Warwickshire Option S1b: Do not identify Green and Blue Corridors within the South Warwickshire Local Plan, and instead rely on the production of the Local Nature Recovery Strategy 2.21. While the Respondent does not object to the identification of Green and Blue Corridors in principle (in accordance with Paragraph 20 of the NPPF), they are not convinced that such designations can be robustly evidenced or justified in absence of the Councils’ Local Nature Recovery Strategy (LNRS). The Respondent would therefore err towards not identifying such areas at this stage. Q-S2: Please select all options which are appropriate for South Warwickshire Option 2c. Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes. 2.22. Developers tend to err towards higher densities without the need for a planning policy requiring such. It is the inter-play of policy requirements and the input of stakeholders that tend to drive densities down rather than developer choice. 2.23. The Urban Capacity Study (October 2022), which forms part of the Issues and Options Evidence Base, identifies the biggest constraint to the maximisation of gross developable areas on sites as being the requirement to provide private and shared parking spaces (Urban Capacity Study, Section 3.3, Page 20). Should the Councils therefore wish to optimise densities, careful thought will need to be given to the implication of other policies and requirements on the ability for developers to build at higher densities. 2.24. With regard to Design Codes, while these can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design and density perspective. 2.25. Since developers tend to err towards maximising the efficiency of sites anyway, the preparation of a design code simply to support intensification would seem a disproportionate response to the issue at hand. It would be better if the Councils focus on the consideration of the wider implications of policies and standards contained in the plan which are known to drive densities down.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire 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. 2.31. While the Respondent recognises the importance of re-using Brownfield land, having considered the options presented in the Consultation Document, Option S3.2a is considered most appropriate in South Warwickshire, with Brownfield sites prioritised only where they are sustainably located and in line with the identified growth strategy. To do otherwise could result in unsustainable patterns of development that would conflict with the overarching vision and strategic objectives of the plan.

Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Y/N/DK 2.32. Yes. The Respondent agrees that growth of existing settlements should be part of the overall growth strategy for South Warwickshire. As opposed to new settlements, sustainable development at existing settlements has the benefit of being delivered without significant infrastructure investment and within a much shorter time frame. 2.33. Turning to Hampton Magna, the Respondent’s site off Old Budbrooke Road represents a logical extension to the village that is immediately available by a housebuilder and capable of being developed without technical impediment. There is capacity within the local primary school and its development would assist in supporting existing facilities to the benefit of the vitality of Hampton Magna in accordance with Paragraph 79 of the NPPF.

Q-S5.2: Do you think new settlements should be part of the overall strategy? Y/N/DK 2.35. Broadly yes. The Respondent is generally supportive of the inclusion of new settlements in the overall growth strategy as they can be an effective way, at least in theory, of delivering new housing where there are barriers to the sustainable delivery of sufficient housing elsewhere. However, in reality, the physical implementation of new settlements is often complex and costly, which can significantly hamper their delivery. The Respondent would therefore caution against over reliance on new settlements in the preferred growth strategy. 2.36. Where new settlements are proposed the infrastructure requirements should be identified and robustly costed to ensure that delivery is viable. The Councils should also take a conservative approach regarding assumed capacity and likely build-out rates and avoid including housing completions from new settlements too early in the plan period. The Lichfield’s Start to Finish (Second Edition) 2020 report may be a helpful starting point in this regard, although any assumptions that are made will need to be fully evidenced having regard to site specific constraints and circumstances. 2.37. To improve choice and competition and help to mitigate the risk and implications of such sites not coming forward within the timescales envisaged it is recommended that a buffer is applied to the housing need, with a greater number of small-medium sites allocated at sustainable settlements to ensure adequate housing delivery in the short-medium term. The Local Plans Expert Group (LPEG) recommends a 20% buffer. 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? Y/N/DK 2.38. Yes. The Respondent considers it sensible to look to rail corridors as a preferred approach to the identification of potential locations. However, given the problems and delays that can often occur with the provision of new rail services and stations, it is considered that the intensification of existing rail services should be considered before new ones. The Respondent’s site to the west of Hampton Magna is an ideal candidate for future housing development in this context given its location within walking distance of Warwick Parkway Rail Station.

Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 2.39. Hampton Magna is included as a potential location for growth under all five growth options, of which the Respondent is supportive. A site-specific representation in favour of the allocation of additional housing development at Land off Old Budbrooke Road, Hampton Magna is set out under Section 3.0 of this Statement. 2.40. Given the emphasis on mitigating the impacts of climate change and reducing the need to travel in order to reduce carbon emissions, it is the Respondent’s view that settlements such as Hampton Magna, which have a good range of services and are located in close proximity to existing railway services, should be retained as a location for growth under all options. 2.41. Considering the evidence base prepared to date, the Respondent would agree that Option 2 (Rail and Bus Corridors) would appear to align best with the overall objective of mitigating the impacts of climate change and, on balance, considers this to be the most appropriate option for South Warwickshire. However, in the interests of maintaining the vitality of existing settlements there is also considered to be merit in Option 5 as a hybrid approach. 2.42. As recognised in the Consultation Document, existing settlements within the Green Belt (such as Hampton Magna) are some of the most connected of all the settlements within South Warwickshire. Considering the magnitude of the housing need and the need to deliver a significant proportion of this on greenfield sites (as confirmed in the Urban Capacity Study) then it is considered inevitable that there will be a need for Green Belt release. The alternative being to limit growth to locations outside existing Green Belt designations, which would unlikely deliver the most sustainable or climate friendly option since it would push development away from areas with the best infrastructure and opportunities for access. To this end, the Respondent agrees that a review of the Green Belt across South Warwickshire will be an essential piece of evidence.

Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Y/N/DK 2.43. No. The sustainability of settlements falling outside of the chosen growth strategy will vary to a significant degree and should not therefore be treated as equal. In the Respondent’s view, a comprehensive settlement audit should be undertaken for those settlements that fall outside the identified growth strategy in order to better understand their functionality and relative sustainability. The results of which can then be used to inform an appropriate distribution strategy across these settlements in a less arbitrary and more transparent way. To do otherwise could put at risk the vitality of such settlements in conflict with Paragraph 79 of the NPPF.

Q-S9: Please select the option which is most appropriate for South Warwickshire Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 2.44. Of the options presented the Respondent considers that a consistent approach across Stratford-on-Avon and Warwick District is most appropriate and would therefore lean towards Option S9b as being the most appropriate option for South Warwickshire. 2.45. The Consultation Document notes that one disadvantage of this option is that some non-strategic land allocations will likely not be made until Part 2 comes forward and that it would be difficult to make appropriate revisions to boundaries in advance of these non-strategic allocations being made. The Respondent does not disagree and considers this to be one of a number of disadvantages in proceeding with a two-tier plan rather than a single one as discussed under Q-P1.2.

I would like to comment briefly on the outline proposals in the above Plan. I am a 77 year old resident of Wootton Wawen, having retired with my wife, Gwyneth, to live in the village 10 years ago. Let me state from the outset that I welcome the concept of more houses being built in the village. Although Wootton Wawen has a great heritage and history, which a major expansion of the village could threaten, and it is not geographically suited to major housing developments, communities cannot stand still, and as it were be preserved in aspic, and therefore more housing creates an opportunity to encourage the development of a younger population, and particularly young families. Wootton Wawen has, as you will doubtless know, a disproportionally high number of people over the age of 65. The key issue to me is: how many houses should be built over the next 25 years? I believe there are presently in the region of 350 homes in Wootton Wawen, excluding the static homes in the grounds of Wootton Hall, and so the figure of 500 additional homes quoted in the draft Plan would if implemented represent an increase of nearly 150% over the current level. That is clearly unacceptable given the physical barriers to building in the village (e.g. flood plains) and the fact that such housing numbers would destroy its essential character and uniqueness. To my mind, a more realistic option would 100-125 homes, although there are caveats even to that reduced figure. The principal issue of caution is based on the fact that housing needs and choices cannot be decided in isolation. If, say, 100 homes is an acceptable premise, then that will mean, say, a minimum of 200 adults, 150 children, 200 cars etc. which in turn could necessitate a new medical centre in the village, an extension to its excellent primary and Junior School, probably greater investment in water provision, drainage and sewage, improved broadband (new masts?), road changes etc. etc.… If, as I comment on below, priority is given to development of Wootton Wawen’s railway station, a car park will be essential, creating the need for more land provision. In assessing the requirement for more housing, I believe priority should be given to affordable homes, not as has been tried before in the village for older people, but for young people and particularly those with young children. And by “affordable”, I mean to include rentable property and shared ownership schemes. There is an existing site (Keyte Gardens) which can be expanded to meet part of this need, but given the age profile of its existing occupants, a better site would undoubtedly be by the railway station which is also close to the infant and primary school. I come back to the station because I think this and the land around it is the key to the future of Wootton Wawen. There are plans in 2024 for there to be 2 trains an hour between Stratford and Birmingham Moor Street, instead of the present one-hourly service. Wootton Wawen is only a “request stop” station at the moment, but with a half-hourly service, and housing and school options, the village becomes a very attractive option for young people whether working locally (and with an increasing population there would be more work opportunities locally) or in Birmingham or Stratford. So I am excited about the future of WoottonWawen (although by 2050 I shall be pushing up daisies in St Peter’s churchyard!) and that future is dependent on new housing, delivered to a plan which includes and embraces all the other factors I have referred to above. But those who decide the village’s future must always remember how special it is, its antiquity , and its unique Warwickshire heritage, and nothing that is decided must allow that to be threatened or destroyed.

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.

Meeting South Warwickshire’s sustainable development needs • Delivering South Warwickshire’s economic needs • Delivering homes that meet the needs of all our communities • A climate resilient and net zero carbon South Warwickshire • A well designed and beautiful South Warwickshire • A healthy, safe and inclusive South Warwickshire • A well connected South Warwickshire • A biodiverse and environmentally resilient South Warwickshire As a holistic aspiration to meet future development needs we are fully supportive of Stratford-on-Avon and Warwick District Councils joint vision for South Warwickshire in terms of housing and job growth, while meeting the above criteria. However, this submission relates specifically to the parcel of green belt land adjacent to Aylesbury Road, Lapworth, B946BE identified as H18 in a previous WDC planning documentation. When considering the suitability of this land for building new dwellings we would ask that the following is taken into your consideration: • Access to and from this land is via a small downhill section of Aylesbury Road close to a sharp bend. Currently, the speed limit of the roadway past the access point is 40mph. This will undoubtedly mean a much-increased collision risk with the through-traffic using Aylesbury Road for Dorridge and Hockley Heath. • The environmental impact of building homes here will also be substantial as the area is overgrown and isolated from human activity. It’s a much-used habitat for wildlife. For example: Foxes (6 have been seen together here on one occasion). Muntjacs, alone and in pairs. Deer. Rabbits and small mammals. Many birds including Owls, Woodpeckers and Buzzards. Small birds’ nest in the extensive swathes of brambles around the land’s perimeter. Whilst there are other important green areas this is the only one that is the sole domain of our wildlife. • The loss of this land to housing could also impact on the natural water retention it currently provides and bring risk of flooding to nearby gardens or even homes. At the moment the land becomes a wetland that releases rainfall slowly and safely. • Aylesbury House is a listed building that has recently been renovated and brought back from dereliction. A past planning objective for its survival was to allow views of the house to be safeguarded from the surrounding countryside. This will be lost if high density house building is permitted. • A public footpath currently passes through the middle of this undeveloped Greenfield site where open space and a woodland area which is valued by local residents who can walk through to access many local country walks. • Excessive tree or hedgerow removal could affect drainage, soil stability and wildlife habitats • Development of this land will clearly impact current public services such as drainage and water supply. • Currently other local infrastructure, such as Primary schools and Medical facilities are inadequate to meet any expansion to the population of both Hockley Heath and Lapworth.