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

I would like to voice my concerns over the plans to review the green belt boundaries in North Warwickshire, in particular to the land near Old Milverton. This land is used daily by the people of Leamington to exercise, my own children enjoying walking, running and cycling here and have done since they were tiny. The land is an important distinction between Leamington and the town of Kenilworth, without this the two towns will merge together and lose their individual and attractive identities. It also isn't necessary to build on this green belt land for the following reasons: ·it's high quality agricultural land which should be protected for future food security ·the planning team have not presented any options aside from building on green belt land, though they have explored these options ·the statistics used in the consultation document to support development are misleading - it says the 54% of respondents support the exploration of the green belt without mentioning that 45% of these respondents were developers, landowners and businesses. With food shortages being experienced more frequently supermarkets, as a country we are struggling to supply food, with more dependence on imports, building of the greenbelt further enforces the challenges experienced. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The land making up these sites is, therefore, considered to be a scarce resource of high value for sustainable food production. The Government seeks to protect against the loss of such land from non-agricultural development. The National Planning Policy Framework is clear that “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality”; a policy which will continue to grow in significance as the increasing cost of imported wheat and grain drives up domestic food production needs.

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.

3.0 Land off Old Budbrooke Road, Hampton Magna 3.1. This Section of the Statement promotes land to the west of Old Budbrooke Road, Hampton Magna which the Respondent can confirm is under the sole control of William Davis Homes and is available for residential development. William Davis Homes 3.2. William Davis Homes has more than eight decades of experience as a quality housebuilder and are proud to have secured the industry’s gold standard ‘5 star’ status − awarded by the Home Builders Federation - seven years running. 3.3. As a housebuilder, with a directly employed workforce, they have the knowledge and capability to bring forward and deliver residential sites almost immediately upon allocation, which is often not the case where a site has been promoted by a strategic land promotion company or landowner due to the need to sell the site on. The Site 3.4. The Respondent’s site is located to the west of the village of Hampton Magna at land off Old Budbrooke Road. Hampton Magna is located approximately 3 miles to the west of Warwick and lies within the Parish of Budbrooke within Warwick District. 3.5. Hampton Magna was originally founded on the site of the former Budbrooke Barracks during the late 1960’s and 1970’s. The village is relatively small and its appearance is of its time but it has a good range of services and facilities including: • Primary School: • Medical Centre: • Post Office and Convenience Store: • Play areas • Community Centre 3.6. The Site itself comprises approximately 21.1 hectares of predominantly arable land, with some pasture and horticulture activity. Of note is its proximity to Warwick Parkway Rail Station, which is situated on the north-western side of Warwick and within a 10-minute walk of the site, along a footway that runs the entire length of Old Budbrooke Road. 3.7. A comprehensive summary of the site’s constraints and opportunities is set out in the accompanying Promotion Document which confirms that there are no technical impediments to the development of the site for residential use. Planning Considerations 3.8. The village is, on the whole, relatively unconstrained in so far as it is not subject to any local or national landscape designation (i.e., SLA, AONB). Nor does it hold any particular value in heritage terms. The village was substantially developed in the 1960s-70s and, as such, contains very few listed buildings and no Conservation Area. 3.9. Whilst Natural England's Provisional Agricultural Land Classification Map indicates that the site comprises Grade 3 Agricultural Land the same provisional classification applies to all the land surrounding Hampton Magna and is not therefore considered to be an insurmountable constraint to development. The site is, however, located within the West Midlands Green Belt which has severely prohibited the village’s growth. Why release land at Hampton Magna from the Green Belt? 3.10. Green Belt is designed to prevent urban sprawl through the unplanned expansion of urban areas. While it is a successful spatial planning tool in this regard, it can have significant implications on the ability to deliver otherwise sustainable patterns of development. In recognition of this, there are mechanisms within National Planning Policy to enable Green Belt Review. 3.11. The Issues and Options Consultation Document (January 2023) sets out five options for growth (1-5) as follows: • Option 1: Rail Corridors • Option 2: Sustainable Travel • Option 3: Economy • Option 4: Sustainable Travel and Economy • Option 5: Dispersed 3.12. It noted that all five growth options include Hampton Magna as a potential location for growth. However, it is understood that the option currently considered to best align with mitigating climate change, following completion of a Sustainability Appraisal, is Option 2. This option is a hybrid of the Rail Corridor and Bus Corridor Options presented at the Scoping Consultation stage. It is therefore expected that improving connectivity and locating development in highly sustainable locations, with access to public transport, and particularly rail, is likely to remain the focus of the joint authorities’ overarching strategy. 3.13. Given that there are so few settlements within South Warwickshire with rail stations outside of the Green Belt it is considered somewhat inevitable that in order to release sufficient land for development within the most sustainable locations with regards to sustainable travel options that there must be Green Belt release. 3.14. Paragraph 142 of the NPPF provides that where it has been concluded that it is necessary to release Green Belt land for development that plans should give first consideration to land which has been previously developed and/or well-served by public transport. 3.15. Hampton Magna is one of only a small number of settlements that benefit from an existing rail station with frequent services to a major urban centre (in this case Warwick, Birmingham and London) and, aside from the Green Belt, is relatively unconstrainted. It is for these reasons that the village has been identified as a potential location for growth under all five growth options set out in the Issues and Options Consultation Document. Why Release Land at Old Budbrooke Road for Development? 3.16. The site constitutes a logical and sustainable location that is consistent with the historic evolution of the settlement and benefits from close proximity to the village’s facilities. The site is within a 10-minute walking distance of Warwick Parkway Station and provides an excellent opportunity to realise the Council’s ambition to apply the principles of the 20-minute neighbourhood. Such benefits also mean making better use of existing infrastructure without significant investment being required. 3.17. The site is ideally situated on the western side of the village and will not lead to the coalescence of Hampton Magna with Warwick. This notably sets it apart from other options considered in the Councils’ Settlement Analysis, particularly the alternatives to the north-east and east of the village which would significantly reduce the visual gap between the village and Warwick in addition to those to the south, which suffer greater heritage implications. Assessment against the Purposes of the Green Belt 3.18. The representations set out in this Statement makes clear that irrespective of the options taken forward in the SWLP that Hampton Magna should be considered as a location for growth despite is location within the Green Belt. Whilst development could be provided outside of the Green Belt, there is a concern that a blanket exclusion on development would be counterproductive to the economic and social wellbeing of those areas within the Green Belt and give rise to an unsustainable pattern of development by pushing development to areas that are inherently less sustainable. 3.19. Paragraphs 137 to 143 of the NPPF provides the necessary guidance for the review of Green Belt. The joint authorities will need to be satisfied that there are exceptional circumstances to justify Green Belt release and should look to release land that does not compromise the five purposes of including land within the Green Belt. A Green Belt Review will therefore be an essential component of the evidence base. Set out below is a brief overview of the performance of the Respondent’s site against these five purposes: 1. To check the unrestricted sprawl of large built-up areas. 3.20. Hampton Magna is not a large built-up urban area, although it is located to the west of Warwick, which is. Given the location of the site to the west of Hampton Magna its development would not have any bearing on the risk of urban sprawl with Warwick and would therefore preserve the function of the Green Belt in accordance with this purpose. 2. Prevent neighbouring towns merging into one another. 3.21. The western expansion of Hampton Magna will not lead to the coalescence of one town with another and, in the particular circumstances of this case, the wider urban area of Warwick. The site is well-contained by mature vegetation and presents clearly defined boundaries which would provide a distinctive and defensible edge to new built form, further preventing the risk of unrestricted sprawl. 3. To assist in safeguarding the countryside from encroachment. 3.22. The extension of Hampton Magna to the west would lead to the expansion of development into the countryside. However, this ignores the location of the site within the urban fridge and how it is already seen in the context of existing development at Hampton Magna. Enhancements to existing green infrastructure and the maintenance of existing Public Rights of Way provide an ideal framework against which defendable boundaries can be designed, limiting the extent of any perceived encroachment into the wider landscape. Development of the site would also provide opportunity for a new and significantly improved defined edge to the village. The broad thrust and function of the purpose of the Green Belt in safeguarding the countryside from encroachment in this location would therefore remain essentially unaffected. 4. To preserve the setting and special character of historic towns. 3.23. Hampton Magna has no recognised historic qualities or character to speak of. The site does not lie within or alongside a historic town, with the closest Conservation Area located 1.2km to the east in Warwick. The western side of the village performs no role in providing a setting for Warwick and is considered neutral in this respect. 5. To assist urban regeneration by encouraging recycling of derelict and other urban land. 3.24. While the site itself is greenfield its release does not in any way disincentivise the urban regeneration of sites elsewhere in the plan area. That said, in terms of the wider issue of encouraging the redevelopment of brownfield land within the plan area, it is simply unrealistic to expect the level of housing proposed to be accommodated on brownfield sites alone. The Urban Capacity Study (October 2022) confirms that it will be impossible to meet the development needs of South Warwickshire without significant greenfield development. It is therefore considered inevitable that both greenfield and Green Belt land will need to be released as has been the case in previous Local Plans. Conclusion 3.25. Given the scale of housing need and the significant consequences for sustainable development within the plan area if Green Belt is not released, the exceptional circumstances threshold set out under Paragraph 140 of the NPPF is considered to be met. Unlike other options, the release of land to the west of Hampton Magna would not compromise the five purposes set out under Paragraph 138 of the NPPF. The release of the Respondent’s land off Old Budbrooke Road from the Green Belt is therefore supportable in principle, unlike other options. Vision 3.26. The Vision for the site has been informed by the site’s location, the unique local character and context and identified aspirations and priorities for the local area, as well as the site-specific considerations and core design principles that will help to inform the formulation of a detailed and high-quality scheme in due course. 3.27. The Promotion Document that accompanies these representations, while it illustrates only one way in which the site could be developed, emphasises the reasons why the site is deliverable and, if allocated, explains how the development will help to meet identified local housing needs and provide meaningful benefits for the local community. Conclusion 3.28. It is clear from the accompanying Promotion Document that, aside from Green Belt, the Respondent’s site at Hampton Magna is not subject to any major constraints and, as such, would be capable of being delivered in a relatively short period of time post adoption of the plan given that the site is already in the control of a housebuilder. 3.29. While the Promotion Document illustrates only one way in which the site could be developed, it demonstrates that land to the west of Hampton Magna would constitute a logical and suitable location for sustainable development and outperforms other available options at the village. Through comprehensive analysis of the contextual, planning and technical parameters it also provides evidence that the site is an appropriate location for development proximate to Warwick Parkway Station, is available now and is deliverable without any technical impediments. 3.30. In light of the above, it is therefore the Respondent’s belief that their site at Hampton Magna is the superior option for the accommodation of new homes at the village and accordingly should be allocated for housing development for around 250 dwellings to assist in meeting the housing requirement of the SWLP in a positive and effective way in accordance with both Paragraph 79 of the NPPF and the tests of soundness set out under Paragraph 35 of the NPPF.

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 S9 Settlement boundaries and infill development. The Pillerton Priors BUAB has been acknowledged as part of our adopted Parish Plan. Issue S10 Any other development strategy issues. SDC and WDC have a big responsibility as they draw up this plan. They need to protect the lovely environment that is South Warwickshire whilst at the same time earmarking areas for development. Developers will want to build in the attractive rural areas rather than towns or brownfield sites. The issue is whether the councils will protect South Warwickshire or whether the developers will win the day.

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. The option presented in the consultation is not in accordance with the NPPF's avoidance of greenbelt development except in exceptional circumstances and is in my personal opinion misleading. 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. The option presented in the consultation is not in accordance with the NPPF's avoidance of greenbelt development except in exceptional circumstances and is in my personal opinion misleading. 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 given viable alternatives. The option presented in the consultation is not in accordance with the NPPF's avoidance of greenbelt development except in exceptional circumstances and is in my personal opinion misleading. 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-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. Development in the North Leamington Greenbelt was proposed in the last WDC local plan and had to be withdrawn, with significant consequences. I feel that the climate emergency might be used to artificially find a different approach to justifying exceptional circumstances, I strongly oppose this as I feel there is no grounding to this approach. 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. Finally, the appendices to the document suggest that extension of Cubbington into greenbelt would have a low risk of urban sprawl, I feel this is incorrect and should be revised. The greenbelt between leamington and Coventry is under significant pressure and already shrinking, I would strongly argue that further development is a significant risk for urban sprawl and certainly the perception of urban sprawl. I would argue that the plan should also look to protect rural farmers and particularly tenant farmers, farming in this country is under significant difficulty and tenant farms offer an important access route for individuals without large landholdings into agriculture. I do believe that when planning housing and employment developments for the district, the employment of farmers and tenant farmers should also be included and they should be protected.

Having moved to Leamington in 2006 I am now very familiar with the area of Green Belt to the north of the town. For me this area is very important because it allows me to walk in attractive countryside within a short distance of where I live. It would be devastating if you allowed this area to be developed so can I formally raise an objection

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 S6: A review of Green Belt boundaries As noted in the plan, the Green Belt washes over a vast area of the South Warwickshire plan area including some of its larger settlements such as Kenilworth and Royal Leamington Spa. We agree that only locating growth to areas outside of the Green Belt is not very sustainable or climate friendly as it means isolating existing settlements in the Green Belt as well as isolating new development from the existing good infrastructure and facilities already located within the Green Belt. As such we propose that the council should allocate small sites to be removed from the Green Belt for development. Our client’s site currently comprises equestrian land located in the Green Belt. We understand that the Green Belt serves five purposes, however we demonstrate below that our client’s land’s contribution to the Green Belt’s functions are limited:  The site does not check the unrestricted of large built-up areas.  The site does not prevent two urban areas merging into one another.  The site does not assist in safeguarding the countryside form encroachment as the site is bounded by the M40 to the east and there is residential/equestrian development to the west. The Council must recognise that on areas (such as our client’s land) that do not hugely contribute to the Green Belt, they should be removed to allow for growth to sustain these areas. As development on our client’s land would not create a huge impact on the Green Belt, it is requested that the site is released from the Green Belt to provide an area for residential development.

Issue S8: Small scale development outside of the chosen spatial growth option 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? Yes, a threshold approach is appropriate to allow for small-scale developments to come forwards. As explained in Issue S8, these small-scale developments are important to preserve the vitality of smaller settlements and we cannot discount the benefits that development schemes may offer such as improved infrastructure and affordable housing. However, we do disagree that small-scale development should not be allocate and instead believe the plan should put emphasis on allocating small-scale developments sites to ensure both the housing need for district along with local housing need is met. We would therefore urge the Planning Authority to consider allocating small sites for development in villages, to support local shops, services and community facilities. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? We disagree with the Council’s proposed limit of 10 dwellings as a size limit for individual sites as this does not allow for development which would reach the threshold for affordable housing. As such, we would recommend that the appropriate size limit for individual sites should be 20 dwellings.

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 is not a valid justification to develop on greenbelt land. It is a weak and bizarre argument as greenbelt is vital for mitigating climate change with benefits such as tackling air pollution, slowing and reducing the impacts of carbon emissions and providing essential habitats for wildlife. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is also 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) 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. 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.

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 S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban 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.

The current, seemingly relentless , assault on Green Belt in our area is a disgrace. Burton Green Parish Council recently exposed the fallacious demographic figures put forward to justify an immense expansion of house building spreading into the Green Belt which, if left unchallenged, will erode the gap between Kenilworth and Coventry turning us into another sprawling suburb and destroying the character and charm of the town. I will wholeheartedly support such challenges. I believe the weakening of Green Belt law and the political ambitions of councils such as Coventry are a major threat to not just the environment and wildlife but the right to live in pleasant surroundings. Currently, Kenilworth is hemmed in by multiple road closures due to HS2, housing and road development which have devastated the surrounding countryside often in a wantonly destruction manner and much to the detriment of the character and charm of the town and county. To a cynical mind this might be attributed to the power and influence of business, capital and revenue rather than the wishes of the local population. Propaganda highlighting minor greenwashing attempts to mitigate this erosion of our countryside or by construction companies to claim they have offset or replaced what took centuries to develop and hours to destroy for ever, are beyond laughable. There is a sea change coming and the backlash will see plenty of councillors lose their seats if you continue to ignore the wishes and interests of the voters.

Please keep the Green Belt north of Leamington - it provides essential, high quality agricultural land, growing wheat which supplies flour for bread and rapeseed important to produce vegetable oil. Crops that have been in short supply because of world events. Removing more fields from crop production will make food supply in the UK much worse. The land also provides countryside footpaths which are important for recreation - improving the physical and mental health of local residents.

QS7.2 I do not think the area around Hatton Station is suitable for development. The country lanes and the junction near the entrance to the station are not safe to accommodate an increased volume in traffic. This would also create extra noise and air pollution. There is currently some green belt between Hatton Station and the M40 and if this was lost it would not only effect pollution but also damage nature and mean loss of home to the abundance of wildlife that live there. This would also have a negative effect on peoples health and well being as many currently use the area for healthy walks in the fresh air etc

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 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.

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. Not only this but development in this area is liable to alter the hydrology of the site closer to the river by creating greater run off and a faster movement of water in the subsoil. This is liable to result in more flooding downstream including that towards the town center of Leamington Spa and beyond. The Climate Emergency can not be used as justification to develop on greenbelt land especially when we have seen so much disruption and damage to biodiversity and habitat as well as on local resident’s lives from developments such as HS2. The development of this land would go directly against every bullet point given in chapter 3.

We are writing to object to the proposed development of the Green Belt (issue S6), specifically the Land at Blackdown, north of Leamington Spa (REFID 174 – loss of 69 acres of Green Belt agricultural land for Housing/Residential). This land is a most desirable and attractive part of the North Leamington area and it would be a significant loss and risk to the wildlife and agriculture area. There is no site access to amenities provided to the South of Leamington Spa, which has already seen a huge increase in housing - of which, plenty are still available. There are plenty of other ‘non’ Green Belt sites available. The loss of this greenbelt land in addition to the loss of Greenbelt land due to HS2 which is in close proximity, it creates a huge increase to the urban area and completely alters the character and enjoyment of the area. In addition, there are very few routes from the north to the south of Leamington - due to the river and railway line, these become easily congested as was felt by the part closure of Princes Drive for bridge works and the gas problems on the old Ford/Vitsoe roundabout. There is also a huge lack of expansion capacity at the closest infant/junior and high schools, where there is already a 3 class entry. The footpath is also very popular and heavily used by dog walkers and families, and the nearest larger park is Ryton pools – which is often shut due to car parking capacity being reached. It is our view that the planning for this site is not in the town’s or the residents best interests.

Q-S3.2 Use of Brownfield Land for development Pillerton Hersey Parish Council considers it important to prioritise the development of brownfield sites where it corresponds to the growth strategy. This may be in the form of residential or infrastructure. Q-S4.1: Growth of existing settlements The Parish Council agrees that the growth of some of the existing settlements in South Warwickshire should be part of the overall strategy. The Council particularly notes the importance of local infrastructure to accommodate growth. For example, schools (primary and secondary), access to primary healthcare, shops, etc.

Development strategy We consider it essential that the building of infrastructure should be implemented before or during development unless it would otherwise represent poor value for money. There have been instances where the existing policy of what is brownfield has been limited development. A suggestion is that if it looks and feels like a brownfield site then a definition of what a brownfield site it should be reconsidered. For example, industrial livestock farming. The principle of the 20-minute neighbourhood is good but there may be occasions when it may be better to not apply it if it would impede a small/micro development that proposes other benefits above and beyond existing standards. Similarly, if a sustainable proposal to develop a rural brownfield site is presented, it may not exactly meet the 20-minute neighbourhood principle but is near and has other sustainable design features. Additional development is needed but there is not a limitless supply of land. It is therefore important to consider intensification, however, this should be both considerate of the local site in question, provide a health, quality environment and appropriate access to other space. There is an opportunity to use a balanced scorecard approach where points are accumulated to compare sustainable, innovative developments. To support appropriate local development, local planning committees should take into account the inherent flexibilities associated with development proposals. The development strategy should ensure that existing and future settlements and development have energy security that is affordable for all. Access to clean, sustainable, affordable, secure energy transcends many other issues in the plan. The potential for individual homes, micro-developments, hamlets etc to be self-sufficient is significant. Homes could not only have their own generation but also shared generation and storage (not necessarily on a large scale). These types of features should be prioritised to support energy security. On the issue of sustainable transport, the parish council considers this could be enhanced if some bridleways were upgraded to promote cycling. This would be particularly appropriate between neighbouring rural communities, particularly to access services. It may be an option to consider support for landowners to include cycling (‘green transport’) under environmental land management (ELM) schemes.

As a resident of the area (Edge Lane, B95 5DS), for five years, I have examined the proposals, and I have some fundamental concerns relating to the proposed plan. This email sets out my concerns in a structured manner, with my comments grouped around key headings. 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 would expand to such an extent that they would 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 space would meet 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. Additionally, 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 its attendant 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.” This is not an argument that supports additional pressure on (a) the road network or (b) resourcing of employment in (and around) Stratford-upon-Avon. 2. EROSION OF 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 Henley-in-Arden) 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 issues – 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 1,750 - 7,000 residents (assuming 3.5 residents per house) 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 three and four times per year. Roadworks anywhere in the town – typically driven by servicing the antiquated drainage system and other infrastructure – currently create 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. This issue was not properly addressed during the last expansion of the town; it barely functions now without the additional pressure of a substantially increase stock of housing. 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 evidently aggressive development proposed for 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. How will this expansion be managed within the existing constraints of (a) land and (b) traffic flows? 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 wholly 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 by any yardstick a 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 Henley-in-Arden 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 demand 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. SUMMARY We acknowledge the need for additional housing in the area. However, proportionality and a consideration for the impact of the proposed changes must be borne in mind. We feel that the current proposals are fundamentally lacking on both counts. 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

South Warwickshire Local Plan - Henley-In-Arden I write on behalf of me and my wife. We are expressing concerns and objections about the proposals contained in the plan by SWLP. The plan is not fit for purpose, it does not take into account the infrastructure issues that we as a community are all ready experiencing. These include green belt development, transport infrastructure and the lack of alternative routes for commuters, school limitations and capacity, medical and health service limited capacities. There are already problems with flooding and sewer supply we do not need to damage what is already in place by adding to the burden of an inadequate infrastructure. We as a community do not need more development we need an environment in which our existing community can thrive. Unless the voices of our local communities can be heard and upheld then you are not honouring your constituents and abiding by the commitments of a local authority to listen to the voices of communities, whose opinions and values are those who live here everyday. To this end we object and would request that this be noted as such at your next meeting.

Issue S1. Green and Blue Infrastructure: Sometimes there is a tendency for planners to over-complicate issues. Warwickshire is blessed with a wealth of countryside and waterways which clearly needs to be protected and incorporated into new development as ‘green and blue Infrastructure’ whether as corridors or not. These do not need to be re-invented just integrated where new development is envisaged. Issue S2. Intensification: Development is better planned at a variety of densities depending on local circumstances. In an urban context, schemes should be designed at a density to support frequent public transport without undermining decent living standards. That may be feasible for new settlements and towns like Warwick, Leamington and Stratford, but is less feasible for the majority of Warwickshire’s existing villages. Intensification may work well in some settings but shouldn’t result in dense development with small gardens whilst developers are expected to provide large areas of wasteful public space which then have to be managed and maintained. Britain has some of the densest and smallest homes in the world. Planners have an unfortunate habit of pushing for increased housing densities – for other people! Issue S3. Brownfield Land: It is a popular myth that there are substantial numbers of vacant brownfield sites waiting to be developed and brownfield sites can satisfy the needs for future growth. Recent work by Lichfield’s for the LPDF shows that brownfield land is more limited in the regions which have high demand. Further north, brownfield land is more plentiful, but not in areas where people necessarily wish to live. Moreover, high density brownfield development can be more expensive and result in the loss of established buildings and embodied energy. In Birmingham, brownfield development has been targeted, but at the expense of affordable housing. Planning policy already steers development to brownfield land where possible, but this usually means losing industry and commerce which then re-sites on greenfield land on the periphery of towns. Warwickshire’s countryside is now covered with distribution depots, especially along the A5 and at motorway junctions. Airfields may be suitable for new villages, but they too often tend to be open and windswept and difficult to develop. It is worth remembering that when PPG3 policy imposed a brownfield-first policy in 2000 (when both Stratford and Warwick Districts had Urban Capacity Studies and moratoria on development), housing delivery fell to its lowest level since the 1st WW. It took the Barker Review and 10 long years to recover. So a more balanced policy is the answer. This solution aligns with S3.2a. Issue S4. Growth of Existing Settlements: Above all, the Council’s should be aiming to provide a portfolio of different sites, in different locations throughout the Districts to meet peoples’ many and varied housing needs. However, this aim seems to have become lost in the technical and somewhat ‘sterile’ analysis of the ideal ‘20 minute neighbourhood’. Sadly, even when facilities are nearby people will always walk to their destination. Sometimes nuclear and more remote rural settlements are better able to meet the ‘20 minute neighbourhood’ ideal. Villages such as Napton or Stockton, with more minimal services (a shop, school and bus service) tend to have closer communities where shopping, schooling and social activities are all done within the same community. Similarly smaller settlements, such as Priors Hardwick and Priors Marston, with fewer services should not be allowed to wither and die. In every settlement, people may travel outside their village for higher order shopping and services and to meet people elsewhere, but the arrival of the internet and home working has changed people’s living patterns so that rural living can be at least as sustainable as urban living. Covid lockdowns have taught us that. The Sustainability Appraisal (SA) appears to have pre-selected 22 large rural settlements based on their technical perception of a 20 minute neighbourhood. It is very concerning that based on this, the Local Plan could just focus on the narrow range of settlements listed in Table 2 ignoring other suitable settlements elsewhere which could otherwise decline. There is no case for a rural de-population policy and the Local Plan needs to take a fresh look at the concept of sustainability to decide whether more rural settlements can benefit from modest levels of development which will help them survive and thrive. Otherwise, if smaller settlements and smaller sites are ignored, the SME builders will be disadvantaged and will eventually go out of business. Issue S5. Potential for New settlements: It is clear from the nature and content of the text, that new settlements are the dream of the planners and politicians in Stratford and Warwick. They may have the advantage of: 1. Dealing with the infrastructure issues by passing responsibility onto the developers, and out-sourcing master planning and funding to someone else, 2. Solving housing needs by focusing development in one or two places, reducing the headache of deciding which settlements could take more, 3. Reducing political pressures and the scale of objections from people who would prefer not to have newcomers moving to their precious villages, 4. Raising the profile of the Local Plan by engaging in ‘big-picture’ planning instead of having to make difficult decisions about specific settlements. However, although new settlements can have disadvantages: 1. They take decades to develop, much longer than either planners or politicians are often prepared to admit. Targets always slip and the developers are then blamed for poor performance and hoarding land, 2. They are ‘resource hungry’ since every element of infrastructure has to be provided from scratch and new facilities and services take time to bed in, 3. They mainly satisfy people who are looking for standardised dwellings and cater for the volume builders. The small local builders don’t get a look in! 4. They deprive the existing settlements of organic growth meaning that they simply wither and die. The characteristics of the villages change – to elitist enclaves. It is a retro-grade step caused directly by planning policies. In short, whilst I would accept that one or more new villages could form part of the Local Plan strategy, the advantages and disadvantages need to be properly explored. The potential locations (which are controversial) need to be properly assessed and the effect of new villages (such as F1, F2 and F3) need to be assessed in terms of their effect on existing settlements. Above all, any new settlement should be part of an overall portfolio which relieves pressure from settlements experiencing over-development – not as forming the central plank of housing policy – nor replacing modest development in rural communities. New settlements should be readily accessible by public transport (preferably rail and bus) and realistic in their build programmes. Councils should not fall into the trap of South Worcestershire Councils where well over half of their housing provision is focused on new villages and major urban extensions which have little or no chance of being delivered within the Local Plan timescale. Issue S6. Green Belts: It is logical that there should be a comprehensive strategic review of green belt boundaries in looking for future development and this will need to occur as part of this Local Plan. In practice however, Government seems to be tightening the scope for green belt review within their national Planning Reform proposals. But in the Local Plans area, several railway stations lie wholly within the green belt and it is sensible that they should be explored as potential settlement locations and not restricted from new development. On the other hand, there are many settlements outside and beyond the green belt which are also suited for new housing lying to the south of Leamington and Warwick. Issue S7. Refined Growth Options: None of the Growth Options are mutually exclusive. They cannot possibly be. One could not base a planning strategy purely on rail-based development (at one end of the scale) or dispersal (at the other). Most of the potential strategies are in fact variations on a different theme. Clearly any strategy must attempt to provide an ‘emphasis’ and ensure that the overall level of housing and economic needs are accommodated. In addition, no strategy should leave rural settlements without some growth or allow them to decline. Sadly, existing settlements seem to have got forgotten and the focus is mainly on large scale growth. Against the background of changing patterns of life, where people can now live and work in rural communities without bus services or shops (and where most shopping is delivered rather than conducted face to face) the survival of village communities has become much more important. Planning should not be erecting barriers to stop sustainable growth. Table 7 which summarises the content of the SA perhaps predictably highlights negative scores for a ‘Dispersal Strategy’ but does not assess the implications of losing services and the potential effects of rural decline. It therefore needs to be examined much more critically. In looking at the various options, in addition to the physical characteristics of the settlements outlined in Chapter 4 – the connectivity analysis, the landform analysis and the density analysis – the Councils also need to carefully consider:- 1. What are the practical implications of focusing development on rail corridors, bus corridors or employment locations. How many journeys are home/work out of the total movements? What proportion of people travel by train (or could travel by train)? Are there other more practical ways of encouraging use of public transport? What about walking and cycling? 2. What % of people now work from home? What % of residents work at all? Is there sufficient variety of sites and locations to cater for people’s needs? 3. What are the social consequences of promoting some settlements and allowing others to decline? Has any assessment of the vulnerability of existing services been undertaken? Option 1. The suggestion that reliance might be placed on a rail-based strategy is superficially attractive but possibly a high-risk strategy when so few people use trains on a day to day basis. Convincing WCC that the railway from Stratford on Avon to Honeybourne could give some life to this strategy, but this would be hugely expensive. The strategy would be reliant on infrequent services unless the rail companies were committed to boosting their services. Some modal shift to trains might occur but this would rely on people moving to longer distance commuting which is arguably running against the trend. Furthermore, this approach seems heavily reliant on 4 new settlements which would need to be developed simultaneously. This would completely undermine the ‘portfolio’ test – ie. the need to provide for a broad range of homes of different types in different locations. It would give a virtual monopoly to the volume builders with the smaller SME builders being excluded as development was concentrated in fewer locations. Option 2. This option makes more sense since it widens the field of locations and enables the use of both trains and buses which are inherently flexible. However, the levels of bus (or rail) service could change at any time – so some clear commitment would be needed from rail and bus companies before committing to this option. Again, this option is focused on bigger new settlements and makes no mention of rural communities. It assumes, naively that because the bus route exists (no matter how infrequent) people will use it for preference – which is unlikely. Clearly a choice of modes is desirable, but more will need to be done in practical terms to persuade people to become regular bus (and/or rail) users. This still focuses too much on big sites and big builders excluding the smaller firms and gives limited choice of housing. Option 3. This option tries to match housing growth with economic growth (and assumes that people will live close to their jobs). This appears sensible but sadly, in practice, people rarely do. Other matters invariably become more important in choosing where to live and many people now are either retired, not employed or work from home and hence journey to work is not an issue. However, this option is in danger of being road-focused and contrary to the Local Plan’s climate change objectives. Again, the strategy seems to focus on new settlements and ignore rural settlements which are the life-blood of Stratford and Warwick Districts. Option 4. This option is a hybrid from options 2 and 3 and therefore theoretically takes the best of both, but again it ignores rural settlements and will consign many communities to rural decline. Again it seems to focus on new settlements and hence fails the ‘portfolio test’ of providing a broad range of sites to meet people varied needs. All the blobs are above 500 dwellings and many are up to 5000 dwellings meaning that, as with the other options 1-3, it is overly focused on big schemes to the exclusion of existing settlements and hence is prejudiced against the smaller SME builders and reduces choice. Option 5. The dispersal option is always rejected by planners (and fails the Sustainability Appraisal Test) because it is assumed that people will travel longer distances on a daily basis. Before rejecting this, the Council’s need to consider to what extent people can, need to and in practice will travel if they are retired, not working, or home based. The promotion and protection of rural communities relies on using existing services and facilities efficiently and encouraging modest but organic growth using smaller builders as well as larger volume building companies. Clearly, a dispersed approach is not compatible for mass housebuilding, but rural communities need to grow to survive and thrive and whatever the outcome of the location strategy. They also need to fill in the gaps of any strategy to ensure that their services are used efficiently and they do not wither and die. (The saving of St Lawrence Primary School in Napton in 1997 was a case study in protecting rural services based on a policy of organic growth). Napton, Stockton, Priors Marston and Priors Hardwick should form an integral part of any dispersal strategy. Issue S8. Small Scale Development outside the chosen growth option: I would warmly support the need to have a ‘small-scale’ growth strategy to support smaller communities and give SME builders a chance to survive and continue trading. Currently Government and planning authorities are paying lip service to supporting SME companies but still imposing policies which have precisely the opposite effect. The Stratford DC policy CS15 is drafted so that smaller communities (in Category F) which are not categorised as limited growth settlements cannot accept small scale schemes unless they are ‘community-led’. This gives far too much power to local people to resist development through ‘parish meetings’ which is effectively a ‘NIMBY’s charter’ which tend to operate as parochial ‘courts of public opinion’ excluding unwelcome outsiders. These are positively archaic and should be replaced. There is no need for an overall limit in terms of the number of houses to be built in rural settlements. A site threshold might be helpful as a guide. Issue S9. Settlement boundaries: Most settlements have tight village boundaries which are drawn around the outer edge of villages and sometime even through back gardens. As a consequence, settlements have no room to grow and gradually die. Services disappear, shops and pubs close and bus services decline or are withdrawn. Local Authorities through Local Plans or communities through Neighbourhood Plans need to take a longer-term view and review village boundaries to allow them to grow organically, as they did in the past.

I warmly welcome the initiative taken by Stratford on Avon and Warwick Councils to produce the Issues and Options stage of the South Warwickshire Local Plan. However, on behalf of various clients, I have deep concerns about the focus of the proposals – in each of the Options – which propose to build several new settlements which will ‘capture’ the housing numbers but doubtless take many years to deliver – thereby starving development in existing settlements at hence will be the expense of the Districts’ rural communities which will inevitably lose their services and gradually decline. The Councils need to think again and consider a broader and more balanced portfolio of housing sites which provide housing opportunities for a wider range of home buyers and occupiers. They also need to consider allocating a variety of sites which will require more work and input from a broader range of SME builders and major builders rather than concentrating development in a handful of large settlements controlled by the volume promoters and builders.

To SWLP Consultation The historic value of the land around Chase Lane north Kenilworth is incalculable, and utterly unsuitable for development, being a historic landscape dotted with patches of what remains of the Forest of Arden. There is a the natural spring that appears to run down the hill, to drain into Finham Brook near Chase Lane. This is all fully referenced by Nic King (I can give you his details) and he has also written about present flooding at Beehive Hill, which would be exacerbated if there’s development. It is also referenced by Steven Falk a nationally known entymologist and landscape historian who has written standard textbooks and completed the Abbey Fields Insect report for the Town Council

We note that only the town and larger settlements have been included in the list of settlements in the consultation document. We consider that housing provision could also be supported from the smaller Category 1 villages. Exisitng smaller settlements would benefit from additional housing development in terms of increasing the local population to maintain and potentially increase local services and provide more housing and choice to local people. Existing settlements will already have at least basic infrastructure which can then be improved and increased. This also then ties in with dispersion of development so that all settlements are taking some housing. We understand that sustainability is centred around the need to travel by private car, and the need to provide environmental benefits, but we would also suggest that the way these elements are thought of need to change, with the change is working culture. Whilst not applicable to all, the levels of commuting have reduced since the Covid-19 pandemic and created a whole cultural change in the way people work and live. The boom in the housing market during the lock down was fuelled by the changes in Stamp Duty, but it was clear that people moved out of urban cities such as London where space is at much higher premium. The HEDNA also confirms this position with the data provided by local agents, which showed that the majority of demand for larger houses were from people moving from larger cities for quieter towns. The rise of online shopping and convenience store home delivery has also meant there is less of a need to live next to services and amenities. From 2025 all new homes will be required to produce 75-80% less carbon dioxide emissions and will need to be ‘zero-carbon ready’ requiring no further energy efficiency retrofit work to enable homes to become zero-carbon as the electricity grid decarbonises. From 2035 the sale of new petrol, diesel or hybrid cars in the UK will also be banned. Existing and future behavioural changes which will result from home working and the ban on fossil fuelled cars, which ultimately have an impact on the levels of air pollution. Sustainable travel has been primarily about the pollution that cars cause, but if in the future cars do not produce that pollution then, this needs to be taken into account when determining if a development is sustainable or not, if the air pollution no longer is an issue.

Henley-in-Arden and Wootton Wawen are the first attractive town and village on the A3400 going south from Birmingham. They are both protected from development by Green Belt policy and this should continue. It is important that their natural and long established character should be protected. Both locations are naturally protected on the west side by the railway line and this natural barrier should be retained to prevent development sprawl. Each location could take on a small degree of development but any such development should be suitable is size, scale and style. It should always be the goal to achieve benefits for the whole community in return for some limited development.

We note that only the town and larger settlements have been included in the list of settlements in the consultation document. We consider that housing provision could also be supported from the smaller Category 1 villages. Exisitng smaller settlements would benefit from additional housing development in terms of increasing the local population to maintain and potentially increase local services and provide more housing and choice to local people through different types of ho. Existing settlements will already have at least basic infrastructure which can then be improved and increased. This also then ties in with dispersion of development so that all settlements are taking some housing numbers and it not will being located in new large settlements. We understand that sustainability is centred around the need to travel by private car, and the need to provide environmental benefits, but we would also suggest that the way these elements are thought of need to change with the change is working culture. Whilst not applicable to all, the levels of commuting has reduced since the Covid-19 pandemic and created a whole cultural change in the way people work and live. The boom in the housing market during the lock down was fuelled by the changes in Stamp Duty, but it was clear that people moved out of urban cities such as London where space is at much higher premium. The HEDNA also confirms this position with the data provided by local agents, which showed that the majority of demand for larger houses were from people moving from larger cities for quieter towns. The rise of online shopping and convenience store home deliveries has also meant there is less of a need to live next to services and amenities. From 2025 all new homes will be required to produce 75-80% less carbon dioxide emissions and will need to be ‘zero-carbon ready’ requiring no further energy efficiency retrofit work to enable homes to become zero-carbon as the electricity grid decarbonises. From 2035 the sale of new petrol, diesel or hybrid cars in the UK will also be banned. Existing and future behavioural changes which will result from home working and the ban on fossil fuelled cars, which ultimately have an impact on the levels of air pollution. Sustainable travel has been primarily about the pollution that cars cause, but if in the future cars do not produce that pollution then, this needs to be taken into account when determining if a development is sustainable or not.