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

Q-S4.1: Existing settlements should not be subject to growth (development) if this means incursions into Green belt land. There are existing settlements that have been subjected to growth in the past. It would seem more sustainable, environmentally friendly and efficient to allow further growth in such areas, at the same time including improvements to infrastructure and facilities. Q-S5.2: I believe that new settlements are probably the best option to go for in the SWLP. The Urban area of Leamington, Warwick and Whitnash (encompassing Bishops Tatchbrook) is already so large that local infrastructure is overwhelmed. I firmly believe though, that new settlements should not be made in the Green Belt , given the large area of non-Green belt availability. It goes against National Planning Policy Framework to see so many new settlement locations in the current consultation document planned for Green Belt land. There cannot be “exceptional circumstances” for all these. Non Green Belt options should be prioritised over any other development options in Green Belt land. New infrastructure can be included in the plan for such non-Green belt sites. Q-S8.1: The threshold approach to small scale development in greenbelt areas may seem an easy way to add to the required housing stock under the SWLP, but I do not feel it should be permitted. You already have limited infill in the Plan. Q-S8.2: Following from my answer to Question 8.1, my answer is zero in greenbelt areas. Issue S6: A review of the Green Belt boundaries was included without the option to comment on it specifically. I wish to comment on it now. I wish to reiterate that using climate change as a reason to amend Green belt boundaries with the intention to permit development is just wrong. If examined closely by legal minds it would prove a weak argument. I am specifically opposed to development of land in the Green Belt area in and around Weston under Wetherley and other similar small green belt villages due to adverse impact on the rural nature of the North Leamington Green Belt. I further feel it is not necessary or appropriate to readjust Green Belt boundaries. In the first consultation on this subject, the exceedingly small number of respondents (561), compared to the population, is hardly a clear mandate from residents of South Warwickshire to redraw Green Belt boundaries. It should not be used as a basis for decision making. It would be interesting to know how many of the responses came from parties that might benefit from development in redrawn boundaries.

Q-S2: As set out at Paragraph 124 of the NPPF, planning policies should support development that makes efficient use of land. Moreover Paragraph 127 states that area -based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places. Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site. We would suggest that there is a need to understand existing housing need in the first instance, the ability for that need to be accommodated in the plan area and the policy response needed to meet that need. The use of design codes is appropriate; however we would caution against an approach that relies on numerous Design Codes needing to be prepared at Part 2 as it could delay delivery. Q-S3.2: The NPPF clearly identifies at Paragraph 120 that planning policies should give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land. Paragraph 141 highlights that before concluding that e xceptional circumstances exist to justify Green Belt boundaries consideration should be given as to whether the strategy inter alia makes as much use as possible of suitable brownfield sites and underutilised land. The test is therefore one of ‘suitabilit y’. The prioritisation of brownfield redevelopment in line with the identified growth strategy, where it can be proven the site is in a sustainable location, or when the development can show that it would have a positive impact on the sustainability of the area is a logical approach. Again, we would suggest that there is a need to understand existing housing and employment need in the first instance to then understand what the appropriate policy response is to meet that need. As set out below in respect of Questions Q-S4.1 and Q-S4.2 the Council’s own Settlement Analysis demonstrates the suitability of some greenfield sites, including CEMEX’s land interest at Long Itchington to have good connectivity and access to services and thus a sustainable location for growth. Q-S5.2: Do you think new settlements should be part of the overall strategy? New settlements could be included as part of the overall strategy for development across the plan period to 2050. However new settlements have long lead in periods and often rely on complex land assembly as well as infrastructure funding and delivery which is out of the control of the Planning Authority. Whilst the plan period to 2050 provides time for any such settlement(s) to come forward, they are likely to be towards the end of the plan period. As such the overall strategy should be positive and proactive and we would suggest that smaller development as well as infill sites are included in order to meet the housing demand. Q-S7.2: Growth Options 1 and 2 rely on the creation of new settlements (6,000 new dwel lings or more) linked to the achievement of new or reopened rail corridors. As set out above, new settlements have long lead in periods, often rely on complex land assembly and in this instance are reliant on notable infrastructure funding and delivery outside of the control of the districts. Whilst the plan period to 2050 provides time for any such settlement(s) to come forward, they are likely to be towards the end of the plan period. There is a pressing need for delivery of housing and economic growth now therefore we would caution against an approach that seek to rely on meeting a substantial proportion of housing need through standalone settlements. In our view in order to meet a range of housing and economic needs and provide a sufficient and deliverable supply of housing land, a mixture of the different options would be preferable. There is a need to enable a steady delivery of sites and housing which meets short and medium term housing needs. Whilst it is noted that the priority should be brownfield, housing numbers are unlikely to be met through brownfield sites alone, therefore sustainable greenfield development sites should be reviewed and included in the overall strategy for delivery. Long Itchington is identified as a settlement/location that may feature in Growth Options 3, 4 and 5. The land south of Stockton Road would therefore be compatible with a number of the Growth Options. Long Itchington is a Category 1 Local Service Village, development of the site would not extend the village any further east than the built out site to the north of Stockton Road. As per the Settlement Analysis, the site is located within 800m of Local Facilities, it has access to all items identified: retail, jobs and economy; places to meet; open space, leisure, recreation – wellbeing; healthcare and education. This means it is one of the highest scoring sites. This shows that the site is a positive development prospect at the edge of the settlement and has good prospect for growth in the context of connectivity and accessibility. In our view there is a need for the SWLP to consider housing land supply in this context and the approach of preparing a Part 1 and Part 2 plans and what this means for the housing trajectory, achieving sustainable growth and meeting housing need. In our view Part 2 should be prepared in tandem, or there should be the allocation of smaller ‘non strategic’ sites or a policy approach that facilitates early delivery to maintain supply. 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? Meeting housing need is likely to rely on achieving housing supply from most settlements. The threshold approach is arbitrary. It is used in the Core Strategy and sets a notional percentage increase for each settlement, however this percentage has been exceeded for many settlements demonstrating that the approach is flawed and does not allow for the future requirement for growth or an appropriate measure or achievement of ‘good growth’. 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? Please see answer to Q-S8.1 which sets out the reasoning as to why the threshold approach is flawed in terms of achieving housing growth across the life of the Development Plan. Q-S9: We would suggest that there is an opportunity for the Council to review settlement boundaries ahead of preparing Part 2 of the Local Plan to see that they are logical and consistent with the growth strategy. The settlement boundary for Long Itchington is incongruous in nature due to the form of development to the north, whilst not including all land which is part of the locality. It is our position, based on the landscape evidence provided in the call for sites, that the inclusion of the site within the settlement boundary would be a logical conclusion to the eastern expansion of Long Itchington that has already been approved and implemented. Such an approach is also consistent with the east west linear nature of the settlement pattern. As noted above in our view there is a need for the SWLP to consider housing land supply and what the approach of preparing a Part 1 and Part 2 plans means for the housing trajectory. In our view Part 2 should be prepared in tandem, or there should be the allocation of smaller ‘non strategic’ sites or a policy approach that facilitates early delivery to maintain supply. A review of settlement boundaries as part of Part 1 could form part of that approach.

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.

Green Belt: This issue was decided by a Planning Inspector after a public hearing quite recently. It is far too soon to reopen the issue now

I suggest that no development is carried out on any Green Belt land until all other options have been exhausted. The Green Belt around Leamington provides high quality agricultural land which helps to provide food security to the UK. A significant number of local people are using footpaths through the Green Belt to access open countryside without having to use a car. The countryside around towns has a particular role to play in encouraging healthy lifestyles and wellbeing. Green Belts provide a breath of fresh air for at least 30 million people who live in urban areas surrounded by the Green Belts. The particularly strong planning controls provided by Green Belt policy provide a clear visual distinction between town and country on the edge of England’s largest and most historic cities, and contribute to a good quality of life within them. Just being able to see an open green landscape is in itself a health benefit. There are also valuable assets for both formal and informal recreation, and 2016 CPRE research showed that Green Belts have particularly high concentrations of public footpaths and country parks, compared to the countryside as a whole. However, some areas of the countryside around towns have been damaged by major infrastructure development, particularly of major roads. These roads can form a major physical and/or psychological barrier for urban residents who want to access the countryside, and this needs to be addressed. There is a need to understand which areas of the countryside around towns offer a combination of good access with tranquillity (a relative absence of noise and visual pollution), and which areas need improvement in this regard.

I am very concerned about the council’s plans to build on farm land near Old Milverton, and also along the A452 from Leamington to Kenilworth. The traffic situation is already bad along this road, new houses would make matters much worse. There would be no countryside between Leamington and Old Milverton, which would lose its identity. This area is vital as a green space for recreation and wildlife, not to mention the loss of farmland which would follow. More houses here require more schools and doctors surgeries which are not always sufficiently allowed for. Recently I had to wait 3 weeks for an appointment to see a doctor at my surgery. The receptionist told me it was because so many new people were signing on from the new estates. Please do not spoil this beautiful area and force local residents to have to move away

I am writing to register my objection to the development on land within “Kenilworth West” and to make clear which land falls within this geographical area: From the Heritage and Settlement Sensitivity Assessment (Sep 2022) it is made clear that from a Heritage perspective “Kenilworth West” refers to: “…the area to the north of Rouncil Lane, which follows the former line of the park pale and the A452...”. The report concludes, “There is little scope for the accommodation of development in this area.” The annotated map (right) shows the location of Rouncil lane (dotted orange line). The call for sites designates an area named “SWLP___12Nov21: Land at Oaks Farm”, Kenilworth”. This is unequivocally located in Kenilworth West (north of Rouncil lane). This land is also clearly within lines of sight (black dotted lines) from Kenilworth Castle (Monument). On this basis – the proposed site should in no way be considered as having any potential to become a preferred option for the South Warwickshire local plan.

Q S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: IM Land consider it would reasonable and logical to consider a range of growth options underpinning a blended spatial strategy, specifically due to the quantum of development that is required throughout the plan period. The level of growth proposed will require the plan to ‘turn on all taps of supply’ to ensure sufficient delivery in sustainable locations across the entire plan period. Land off Rumbush Lane, Earlswood logically falls within Option 1 (Rail Corridors) and Option 2 (Sustainable Travel), two options which should be included in any emerging spatial strategy. It is considered that locating development adjacent to railway stations can ensure that growth is focused on the most sustainable locations, where facilities and connections are already available. It represents an opportunity to maximise existing transport infrastructure and ensure there is a genuine choice of transport modes offered (NPPF para 104 and 105). It is expected that the SWLP area will not be able to meet its needs solely from brownfield or non-Green Belt land, therefore exceptional circumstances will be demonstrated to alter Green Belt boundaries to meet hosing needs. In this context NPPF para 138 states that:“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and/or is well-served by public transport”. Indeed the Councils’ own evidence base supports locating growth at land off Rumbush Lane, Earlswood. The GBBCHMA commissioned Strategic Growth Study (2017) identified opportunity areas where growth could be located to meet the housing needs of the wider HMA. An area ‘South of Birmingham’, a broad, non-specific area of land between Birmingham and Stratford upon Avon (location NS5) was identified as having potential for a new settlement. Land at Rumbush Lane, Earlswood is located within the ‘South of Birmingham’ opportunity area. It states that the methodology was “applied to rail corridors where there is sufficient land such that development would not result in the physical coalescence between the new settlement and an existing town”. Q S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire. M Land generally support the broad vision and strategic objectives for the distribution of development set out in the Issues and Options document. However, to meet this vision, it is important to ensure that growth is distributed towards the most sustainable locations. As per our response to Q S7.2, any spatial strategy must include Options 1 (Rail Corridors) and 2 (Sustainable Travel), as they represent appropriate locations for growth adjacent to existing railway stations. Land off Rumbush Lane, Earlswood is a sustainable, deliverable opportunity which fits within both options.

Q-S2: Please select all options which are appropriate for South Warwickshire Option S2a: Identify areas considered particularly suited to intensification development and develop a design code for each character area. Have a policy supporting intensification within these identified areas where it complies with the relevant design code. 2.1 Whilst we do not wholly object to the use of some intensification (S2a), we do not consider it is a tool which can reasonably be used too widely (S2b). Intensification is likely most appropriate in locations which can utilise Transit/Transport Orientated Development principles, so in those locations within close proximity (no more than 800m) to existing transport hubs, particularly train stations. There may be some opportunities through the development of new hubs or interchanges to utilise this. Beyond these locations, generally we consider intensification (S2c) to be inappropriate for most locations across the Plan area. Such developments were utilised considerably in the 1990's and 2000's and many such places suffer due to car prevalent street scenes and lack of public realm and amenity space. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 2.2 Yes, it is considered vital for the long-term vibrancy, vitality and balanced demography of settlements that they receive a commensurate level of growth through the Plan period. Organisations such as a the CLA (Strong Foundations, 2018) have clearly demonstrated the harms arising when communities are not attributed sufficient growth, or have been declared unsustainable, thus restricting growth almost entirely. Not allowing growth in settlements with a service offer ultimately leads to a patterns of ageing, gentrification and the decline of rural services, facilities and public transport routes. It is difficult to see therefore how a strategy could reasonably or sensibly be advanced which does not provide for commensurate growth throughout the spatial strategy. Q-S5.2: Do you think new settlements should be part of the overall strategy? 2.3 Whilst again we have no inherent objection to the promotion of a new settlement as part of the overall strategy, care must be taken when establishing both whether the new settlement would be deliverable (having regard for infrastructure costs, land ownership and phasing), and if so, when it will be delivered and at what rate of delivery. It is a common pitfall of modern Local Plans that Plan's place a high reliance on the delivery of new strategic development which inevitably takes significantly longer than anticipated within the Plan's trajectory, thus resulting in shortfalls in delivery, both in total quantum and five-year supply. 2.4 Having regard for the proposed Plan period, there is significant time to ensure that a new settlement has sufficient lead in times and a sensible rate of development, as a facet of the overall planning strategy and distribution, rather than the key individual pillar for delivery. 2.5 Subject to sensible assumptions in respect of build out rates in the trajectory, and significant evidence on delivery and viability (not reliant on grant funding which cannot be guaranteed for example), we have no objection to the identification of a new settlement as part of this Local Plan. Delivery should not be anticipated until the mid 2030's having regard for the quantum of work needed, including the progression of the Local Plan, determination and approval of planning applications, infrastructure delivery, groundworks, etc, before real delivery will commence. We will however object if there arises a significant and unrealistic reliance on delivery, or if insufficient evidence is provided regarding the deliverability of any new community proposal. Issue S6: A review of Green Belt boundaries 2.7 Whilst no specific questions are asked within the consultation document relating to the undertaking of a Green Belt review, we would make the following comments. Whilst we support the use of a Green Belt review being undertaken, to increase the Council's background evidence base in respect of the Local Plan, the Council are reminded that Green Belt should only be removed in exceptional circumstances which will need to be clear and demonstrable, particularly in the context that the authority is not washed over by Green Belt and thus there are significant opportunities for delivery of needs without Green Belt release. Specific justification would be required to demonstrate why the release of Green Belt was exceptionally required against such non-Green Belt delivery, including justification for every single site proposed for release from the Green Belt. 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? 2.13 With the exception of minor hamlets with no service offer, we do not believe a strategy should be adopted which excludes commensurate growth in such settlements as discussed in our response to Q-S7.2. If such a strategy is adopted, then the Plan must make reasonable provision for sensible growth in more rural settlements which have a service offer. A threshold approach could be appropriate, albeit rather than a dwelling limit, which is relatively arbitrary and does not allow for sensible planning judgement, we prefer an approach wherein the limit is variable and can depend upon things such as host settlement size or sustainability. For example, settlements can have suggested percentage growth tolerances, such as 15% increase in the number of dwellings for example. These however should be advisory, and never hard caps as this is not consistent with the NPPF, particularly over a significant Plan period. This approach will offer more flexibility in the market, and support and encourage a more buoyant SME housing industry. This approach is fundamentally more flexible, proportionate and positive than an arbitrary dwelling target, which will not reflect the various sustainability credentials of each settlement, nor any specific local opportunities which may arise through the Plan period. 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? 2.14 As discussed in relation to Q-S8.1, we do not believe that a threshold approach should sensible use as blunt of a policy tool as a 10 dwelling limit, or variation of that approach. This is highly inflexible and may provide false security that 10 dwellings is acceptable in small settlements, and an unacceptable limit in larger, more sustainable settlements where sites may reasonable deliver over 10 dwellings, or may better take advantage of the site being developed for example (in accordance with Chapter 11 of the Framework). Such as the availability of a suitable site that can be appropriately be fully delivered for 14/15 dwellings should not be restricted from doing so due to an inflexible policy approach. 2.15 Another issue with the enforcement of a 10 dwelling limit is it will limit the contribution made in terms of tariff style 106 contributions and affordable housing. This means communities will grow, but without the associated contributions were required for local service and infrastructure improvement. 2.16 A unit limit is ultimately entirely arbitrary and the Council should seek to introduce something which is both flexible and positive in approach if they do not intend to allocate to themselves, to ensure the benefits of growth are spread throughout the Plan area and to ensure the Plan is as robust, flexible and positive in its approach. 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 2.17 Having regard for the proposed Plan period, it is considered inappropriate to not consider the appropriate settlement boundaries for all settlements. Clearly settlements evolve and change over time, as they have done in some cases for hundreds, if not thousands of years. As a policy tool, settlement boundaries can function to intensify and urbanise settlements, where they may be better served to grow slightly and commensurately. Whilst positive allocations, or a sensible approach in respect to a policy for allowing settlements to grow is preferable, this should be done alongside a sensible review of settlement boundaries to suitably serve them for the Plan period. 2.18 If the Council is to not critically examine settlement boundaries, or adopt positive policies enabling commensurate settlement growth, we will object to any windfall allowance as clearly suitable sites within a settlement is a finite resource and cannot be expected to continue delivery in perpetuity.

3.1 Please refer to our previously submitted Call for Sites form and site location plan. 3.2 We have supported the identification of our client's land east of Shuckburgh Road, Priors Marston as a reserve site in the emerging Stratford Site Allocations Plan. This site is a logical and sustainable extension of the settlement and can come forward early in the Plan period as an allocation, or as early release reserve site - a fact acknowledged by Stratford Council’s initial timescales for the site (within the emerging evidence base), being able to begin delivery within 1-5 years. 3.3 In respect of the site's constraints, Stratford Council has initially set out that the site is generally unconstrained. The assessment claims that there is a TPO on the western boundary of the site, however there is no specimens onsite so must have been removed or died prior to the TPO being digitised. As a result, there would be no harm arising from development of the site. The SHLAA assessment should be amended as such. A tree survey will be completed, and sufficient root protection zones established with regards to other such trees onsite to inform design proposals. Whilst the Council then subsequently raised concerns in respect of heritage harm, evidence is being produced to demonstrate the level of harm is on the lower end of the spectrum and with mitigation through design, certainly not sufficient to warrant that the site should not be allocated or developed. 3.4 In respect of the Public Right of Way adjacent to the site, this forms the site's eastern boundary. Again, this will inform design proposals. Whilst the site is judged to have a medium impact on Agricultural Land Quality within the Council's evidence, the proposed site is relatively small, and will make a negligible impact on overall supply of agricultural land. 3.5 The site is also judged to be inside a special landscape area, however this impacts every site within Priors Marston. Development would be restricted to the southern edge of the site, where it will be seen in the context of the existing settlement. The Stratford Landscape Sensitivity Study (2012) sets out that ''This zone comprises part of an area of intensively managed mixed farmland, that has lost most of its historic field pattern enclosed by woodland and landform. Henry's Wood plantation strongly divides the zone, with the field to the south more associated with the settlement and enclosed." Furthermore, any scheme will be supported by appropriate boundary treatments, which will further lesson any impacts. 3.6 The site is adjacent to Priors Marston Conservation Area, however, the neighbouring dwellings on Shuckburgh Road are predominantly more modern properties, and as such new development will be seen more in this regard, rather than the older core of the village. It is considered that a high-quality, landscape and constraint led scheme, will have less than a significant impact on the Conservation Area, and any impacts will be marginal and localised. It should be noted that the landowner is committed to delivering a high-quality scheme on the site and has opted to self-promote rather than use a land promoter, in order they will have the final say on which builder is selected to deliver the dwellings onsite. This commitment to quality cannot be guaranteed on other sites and will ensure a high-quality development is brought forward which will add to the village in a positive way. Such delivery would add a mix of houses to the village, vital to ensure that there remains a healthy, mixed population. The provision of affordable housing will also be highly welcomed, particularly given the lack of affordable delivery in recent years. The provision of new housing is vital in such communities, and will assist in supporting local services and facilities, which have been lost in other settlements. The site is a short walk into the village, along the adjacent Public Right of Way, which extends from the eastern boundary of the site southwards into the village to the church, village hall and public house. This enables a fast and safe route into the village without the need to use the main road. This route can be improved as an integral part of development proposals. 3.7 The proposed development of the site respects the villages form and character, as well as historic growth patterns, as shown on the Priors Marston Conservation Area Review. Growth to the west beyond the existing building line would create an unusual and unwarranted intrusion into the countryside, whereas growth to the east would not fit with the loose grain of the settlement's built form. Development to the east is likely to have a greater impact on the Conservation Area in that there are a number of key listed buildings to the east of the settlement. Development on land south of Hellidon Road would have a significant impact on the Conservation Area, given this is a key open space in the centre of the village. Many of the sites at Priors Marston within Stratford Council's Call for Sites register are disconnected or poorly related to the existing built form of the settlement. 3.8 On the above basis, it is considered that the site East of Shuckburgh Road remains one of the most favourable sites in Priors Marston and should be considered for allocation as a part of a dispersed pattern of development adopted within the overarching spatial strategy of the emerging joint Plan. The delivery of 20-30 dwellings is considered entirely proportionate to the size of Priors Marston and would constitute a commensurate and sustainable level of development. The delivery of these dwellings could provide a mix of houses to satisfy local needs, providing family housing and housing suitable for downsizing. The scheme could deliver a policy compliant level of affordable housing, which otherwise may not be delivered in the village. The site had already been assessed as acceptable in the emerging Stratford Site Allocations Plan and this position is expected to return on submission of heritage evidence. This Plan therefore offers an opportunity to ratify the site as an allocation as part of the emerging joint Plan.

Bearley already has a Village plan in place, so how can this be so drastically changed if it has been agreed by the Council that this was acceptable in the first place.? The feedback on the questions solely relate to Bearley and I feel a proper survey of the Village has not been conducted for the proposed areas outlined on your map- in fact it appears the designated areas over most of Warwickshire have simply been coloured in without any foresite or proper thought. 1. It states Bearley train station runs to Earlswood, Warwick along with other locations. This is simply not true. In fact Bearley was reported about not so long ago as being one of, if not the quietest train stations in Warwickshire due to the lack of Trains going through it. It simply cannot be classed as a useful transport link for the village. 2. There is no mention of the newly planted Heart of England Forest which sits within Bearley. Surely an area like this - within greenbelt (as is the whole of Bearley Village) should not be disturbed or encroached upon by development. 3. There is no regular Bus service within the Village. 4. There are no real employment opportunities within the Village, therefore an increase of housing and people would only add to more cars having to take journeys to peoples places of work - which would impact even more on the environment. 5. There is no school in Bearley - so again - parents have to use cars to take their children - adding to the environmental comment above. 6. There is no shop in Bearley - again increasing car use for people. 6. The current state of the road running through the Village is in a bad state of repair with lorries churning up the edges as well as blocking traffic. More development would increase this traffic flow and make the situation far worse. The repairs are not being done now, so how would the Council ensure they were completed when things deteriorate even more. 7. Other than speed signs, there are no traffic calming facilities which leads to extreme speeding through the village on many occasions. The road is dangerous already, so more traffic would only increase this risk to pedestrians and other motorists alike. I feel the residents have had absolutely no information given to them to make any kind of informed decision or choice as to how the Village could be developed for the future, other than the map showing swathes of land carved out for buildings of some sort. The village plan was supposed to allow villages to steer how development was to take place where they live and I feel this option has simply been overruled. Bearley Village is completely washed over by Greenbelt, has conservation areas within and is surrounded by food producing farmland. UK farming is something the government are desperately trying to increase from a self-sufficiency persepctive, which again does not really make Bearley a suitable area for large housing development.

Q-S4.1 - Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, the main delivery mechanism for the growth strategy should be growth at existing settlements in order to not rely solely on new settlements. The potential for growth at Stratford is supported as it is already recognised as one of the most sustainable settlements within the consultation papers and within existing policy. Land at Clopton Quarter lies adjacent to Stratford and adjoins the A46. It is a highly sustainable location for new residential growth and will bring a host of benefits including: - A leading example of a 20-minute neighbourhood by virtue of its sustainable location. - 700 units, including affordable housing. - 40% of the site designated as multi-functional green / blue infrastructure (14ha) - Biodiversity net gain and ecological enhancement. - Restoration of the Vale Orchard landscape through new orchard planting with native fruit trees. - A new, mixed use pedestrian gateway into the Welcombe Hills Country Park. - Infrastructure improvements to the highway network. Q-S5.2 - Do you think new settlements should be part of the overall strategy? We remain cautious and advise against the allocation of new settlements to the extent that it would result in an over-reliance on them for the delivery of housing in the short – medium term. Other sites such as land at Clopton Quarter will be able to come forward quicker and would ensure a buffer should any new settlements fail to deliver, as they often do. Realistic delivery rates should be considered. There are numerous examples of where plan have failed because of the inclusion of new settlements (for example, Uttlesford and North Essex), therefore we oppose new settlements. Any development towards Long Marston as part of a new settlement and any further development off Banbury Road / the A3400 to the southwest of Stratford would be reliant on the completion of the Southwest Relief Road. This road was rejected for Housing Infrastructure Fund (HIF) funding and whilst the Cala scheme has contributed £45million towards the road, there is a funding gap of £86million with no clear delivery mechanism. Without this road further development will create chronic traffic problems in the centre of Stratford as the only way to join the A46 would be to use Bridge Street / Bridge Foot. Traffic along this route would be increased to an unacceptable level. 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? We have no objection in principle to rail corridors being the preferred approach to identifying potential locations for growth and Land at Clopton Quarter would fit with this growth strategy. Land at Clopton Quarter to the northeast of Stratford, south of the A46 would suitably fit with a rail-based growth strategy given that it is in close proximity to the Stratford-upon-Avon parkway both by car but more importantly by pedestrian and cycle connections being a 10-minute walk from the centre of the site. Our Vision Document at Appendix 2 shows the creation of pedestrian and cycle routes to the A46 and through to Birmingham Road towards the parkway. Q-S7.2 - For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 1) Option 1: Rail Corridors 2) Option 2: Sustainable Travel 3) Option 3: Economy 4) Option 4: Sustainable Travel and Economy 5) Option 5: Dispersed All growth strategy options include growth at Stratford, therefore in principle we agree that growth should be accommodated at Stratford, however we disagree with the proposed growth location shown in orange to the northwest of Stratford for each option. The orange shading showing the growth location at Stratford for each growth location should include growth at the northeast of Stratford and include Land at Clopton Quarter. The reasons for this are set out earlier in this response at our answer to question Q-S4.2. QS9 - Please select the option which is most appropriate for South Warwickshire: 1) Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. 2) 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. Option S9b is preferred. We welcome a review of settlement boundaries where relevant in order to accommodate the strategic growth at this Part 1 stage and to assist with the smaller scale allocations to come forward within the Part 2 plan.

Conclusion To conclude, Land at Clopton Quarter sits to the northeast of Stratford within the assessed ‘Broad Location for Growth’ B.26 ‘Stratford Northeast’. We consider the extend of the Stratford North-East Broad Location for Growth to be unrealistic given the landscape and heritage constraints which lie further east / southeast of the Clopton Quarter site. Therefore, the land under our control at Clopton Quarter should come forward as a standalone extension to Stratford for the reasons set out in detail in this response. The site will deliver the following benefits: - A leading example of a 20-minute neighbourhood by virtue of its sustainable location. - 700 units, including affordable housing. - 40% of the site designated as multi-functional green / blue infrastructure (14ha) - Biodiversity net gain and ecological enhancement. - Restoration of the Vale Orchard landscape through new orchard planting with native fruit trees. - A new, mixed use pedestrian gateway into the Welcombe Hills Country Park. - Infrastructure improvements to the highway network. In addition to the site being suitable for development in itself, it is also important to highlight that it is the only logical location for further growth at Stratford, and Stratford must take some growth. Whilst the land to the west / southwest / south / southeast is not designated as Green Belt, these areas bring their own problems in delivering sustainable development in Stratford. Land to the south of the racecourse is designated as Flood Risk Zone 3, and so would not be suitable. Any development towards Long Marston as part of a new settlement and any further development off Banbury Road / the A3400 to the southwest of Stratford would be reliant on the completion of the Southwest Relief Road. This road was rejected for Housing Infrastructure Fund (HIF) funding and whilst the Cala scheme has contributed £45million towards the road, there is a funding gap of £86million with no clear delivery mechanism. Without this road further development will create chronic traffic problems in the centre of Stratford as the only way to join the A46 would be to use Bridge Street / Bridge Foot. Traffic along this route would be increased to an unacceptable level. Any further development to the west would be further away from the centre of Stratford and would thus be less sustainable. It would also bring unacceptable heritage impact to Anne Hathaway’s Cottage and the surrounding area. Further development to the northwest would also be too detached from Stratford, leading to unsustainable development and an over-reliance on the car. This area has no defensible boundaries and the release of this Green Belt land would result in unrestricted sprawl into the open countryside and it is severed from Stratford-Upon-Avon by the A46, meaning that residents would be separated with no permeability into the town. This location is also further from Stratford than Clopton Quarter, meaning it is a less sustainable option. The site is acceptable in heritage terms and is a logical location for growth considering that the other locations around the edge of Stratford are not suitable and will lead to unacceptable highway impacts. We therefore request that Land at Clopton Quarter is considered in isolation, excluding the remainder of the potential Broad Location for growth, as a suitable residential allocation within the South Warwickshire Local Plan. Therefore, Land at Clopton Quarter should be released from the Green Belt and be allocated for up to 700 units for the reasons set out in this representation. We will be engaging with the Green Belt Review process once this commences.

1. USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: Henley-in-Arden is a unique town that was granted town status in12th Century enabling it to hold a market. This was highly successful and included livestock, horse auctions and a famous annual Turkey auction at Christmas. This was very well run and popular throughout Warwickshire. Since the loss of our market and the building of houses on the site Henley has lost most of its Retail businesses and relies now on its Restaurants, Cafes, and unique Ice Cream parlour. Attracting people from Birmingham & West Midlands. Development would destroy the Village appeal that is so popular with our visitors. Henley lies between two much larger urban developments in a section of Green Belt land which serves to prevent urban sprawl extending such that the developed envelopes extend to such an extent that they join. To the south, there is extensive white space on the outskirts of Stratford upon Avon, for example, which is ideally suited to development that meets the needs of a modern economy that is responsive to the environmental demands and the new working patterns that have emerged as imperatives in recent years. Development of brownfield sites around existing urban envelopes is consistent with modern planning policy that co-locates living, working and leisure spaces, and preserves the integrity of the nearby Green Belt and all its benefits. Stratford District Council itself highlights the evidence that supports this argument: “Unemployment across the District is low, with 0.3% of workers claiming jobseekers’ allowance in May 2016. This is lower than the UK average (1.8%) and West Midlands average (2.2%). There is an imbalance between the number of jobs in the district and its working population. An increasing number of residents commute to Birmingham/Solihull for higher paid employment outside the district, while lower paid jobs are often filled by people coming into the district from adjoining areas. These commuting patterns impose significant pressures on the road network. Employers in and around Stratford-upon-Avon can struggle to recruit staff into lower paid and part time roles and cite the absence of affordable commuting options, particularly outside of peak travel times, as a barrier to filling vacancies.” 2. ERODES THE COMMITMENT TO THE PRESERVATION OF THE GREEN BELT The West Midlands Green Belt wraps around Birmingham, the Black Country and Coventry and extends to a ring of towns beyond the conurbation. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the district boundary with Redditch (apart from small areas of land to the west of Mappleborough Green), Bromsgrove, Solihull, and Warwick. The settlements of Alcester, Henley and Studley are excluded from the Green Belt. Commitments from Stratford and Warwick in the existing planning frameworks reiterate a commitment to the integrity of the Green Belt and the prevailing government guidance and policy in respect of the Green Belt. It is critical that the Green Belt around Henley is preserved for its environmental benefits and the health and social benefits that it brings to residents and visitors who collect here to walk/hike. The proposed development is inconsistent with commitments made in the existing planning policies. 3. SIGNIFCANT INFRASTURCTURE LIMITATIONS AND CONSTRAINTS Traffic Limitations: Although existing Plans to Match funding has been secured to calm traffic on the High Street in an initiative to impose during the first six months of 2023 a 20-mph speed limit on the High Street and commuter ‘rat run’ cul de sac roads that lead off the main artery. It is counterintuitive to simultaneously restrict the flow of traffic through the town – a demonstrated need in response to recent traffic safety issue – and at the same time expand the volume of traffic resulting from increased housing development around the town. The frequent holdups on the M40 and traffic accidents on Warwick/Henley Road, result in major traffic using Warwick Road that leads into Henley via Claverdon. This results in us not being able to access the Warwick Road via Edge Lane and drive towards the village during these periods or to get home from the east of our lane. Poor Bus Links: The bus and train infrastructure are insufficient - Where is the bus service direct to Birmingham! Before considering an additional 2,000 residents which might result from the proposed development address a direct bus service from Stratford upon Avon to Birmingham City Centre. Students studying in Birmingham have no direct bus route. 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, using the north-south axis along the High Street. Statistics show that the M40 is the subject of a temporary closure between 3 and 4 times a year. Roadworks anywhere in the town – typically driven by servicing the antiquated drainage system and other infrastructure – currently creates significant delays in the town. Additional development will have an adverse impact on the existing street scape within Henley. Inability to Expand or Widen Existing Roads to Accommodate Traffic: Henley-in–Arden is a medieval market town with a strong architectural heritage reflected in the North – South Road axis and the listed buildings which line the A3400 and High Street. The listed buildings which exist along the main roads in the town preclude any expansion or widening of the road to accommodate increased volumes of traffic arising from increased development and volume of housing. Road Safety: An increase in development in or around Henley-in-Arden will lead to an increase in traffic of all modes to service population movement around a market town based around two intersecting roads. A brief review of the traffic accident statistics for Henley in Arden for the last five years shows 25 incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all of which centre on the High Street and the crossroads at the South of the town. Where the High School is located. An increase in population of the scale proposed by the draft Plan would inevitably lead to an increase in road traffic casualties. Car Parking: Car parking is an acknowledged problem in Henley-in-Arden, where the existing historic housing prevents the development of extensive car parking and on-street parking on the High Street predominates and cars have been forced into small off-street parking facilities – such as that behind the Co-op store. The proposed plan makes no accommodation for the resultant car traffic that would be generated by extensive development around the town. Air Quality and the Environment: Development of the scale proposed will have a disproportionate and adverse impact on air quality and other factors driven by additional traffic from the aggressive development proposed by the town on Green Belt land. 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 Police and Fire Service. Henley in Arden School is part of the Arden Multi-Academy Trust. It has a capacity of 700 pupils and yet already has 710 pupils enrolled. Expansion would inevitably be necessary to sustain development of the extent proposed and local government would need to provide funds. The existing medical practice moved from the High Street to the existing site in 1990, and access is via a footpath from the High Street or via car through a housing estate to a council run car park. Again, the site of the existing facility and the lack of potential for expansion into surrounding space means that expansion in Henley-in-Arden would require a new medical facility in a new location. Any expansion of either of these facilities or the commission of new sites would inevitably lead to an increase in the risk of road, pedestrian, and traffic incidents as a direct result of the crossroads and road configuration which dominates the town. 5. ABSENCE OF A FOCUS ON LOCALISM: The outline proposals make no reference to even the sense of the principles of localism in the Henley-in-Arden community and run contrary to local sentiment. Those responsible for the development of the plan must provide opportunities for communities to influence decision-making. support placemaking and. deliver services that reflect local requirements. We have lost our beautiful library and had it replaced within a small church with opening hours much reduced. We have no Ambulance service and no Police Station (all lost by previous cuts) The scale of the development proposed is completely inconsistent with the scale of the existing town and the development of the population to date. Between 1975 and 2015, the population of Henley grew by 14.3%, and grew even more strongly in later years where between 2000 and 2015, it grew by 10.2%. Using data and projections from: • JRC (European Commission's Joint Research Centre) work on the GHS built-up grid • CIESIN (Centre for International Earth Science Information Network), the population in 2022, stood at 2,571. Assuming an average of 3.5 heads occupying a lower estimate of 500 additional houses in Henley-in-Arden as proposed in the Plan, the population of the town would grow by 68%, which is completely disproportionate development. The plan ignores Stratford Council’s own observations about the importance of Henley’s heritage and the impact of further development upon it. The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan of September 2022 observes that “The setting of some of (the) assets, particularly the castle and church, are still currently experienced within the historic open agricultural landscape. It is therefore recommended that development of the land beyond the north-eastern edge of the settlement should be avoided.” There are also similar observations about the land to the south-east and south-west of the town which are completely contrary to the scale of the development proposed in the plan. Similarly, there is little consideration of the sites north of the Warwick Road (reference HEN.02 in the Stratford Heritage Assessment) where the RED assessment risk of both harm to surviving Ridge and Furrow and harm to archaeological monuments runs contrary to the proposed sites offered for development to the East of the town. The economy of Stratford upon Avon is delicately dependent on visitors and those in search of rural tourism – the strength of demand is such that the town has its own Heritage Centre for visitors and queues for the locally-made ice cream regularly generate queues that extend up the High Street. Extensive development of the type which is proposed would jeopardise local businesses and a tourism-centred town: Solihull was originally a pleasant town in the Green Belt – literally ‘Urbs in Rure’ – but development without reference to local concerns has let it evolve into something much different. 6. INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable. References: 1. Traffic calming: https://www.stratford-herald.com/news/henley-in-arden-to-get-20mph-speed-limit-along-high-street-9280462/ 2. Bus Frequency: Stagecoach timetable 3. Traffic accidents: https://www.crashmap.co.uk/Search 4. Bus Infrastructure: https://www.stratford.gov.uk/doc/206646/name/Adopted%20Stratford%20Area%20Transport%20Strategy.pdf 5. Impact of Traffic on Environment: https://www.stratford.gov.uk/doc/206646/name/Adopted%20Stratford%20Area%20Transport%20Strategy.pdf 7. SFRA: https://www.stratford.gov.uk/planning-building/water-and-flood-risk.cfm

As a resident of Wootton Wawen I strongly object to the building of up to 500 new homes on account of many of the proposed sites being on green belt land reserved for agricultural use as well as putting a major strain on the infrastructure and community services. I would also highlight the following material objections: • Overlooking/loss of privacy • Loss of daylight/sunlight or overshadowing • Scale and dominance • Layout and density of buildings • Highway safety • Traffic and parking issues • Drainage and flood risk • Noise, dust, fumes etc • Impact on character or appearance of area • Effect on listed buildings and conservation areas • Effect on trees and wildlife/nature conservation • Impact on the community and other services

Introduction and Overview We write on behalf of CEMEX UK Operations Ltd (CEMEX). CEMEX is a global supplier of construction materials. CEMEX has extensive land holdings within Warwickshire which include the former Southam Cement Works which is promoted for an employment led Garden Village through the emerging South Warwickshire Local Plan (SWLP) and a ‘call for sites’ submission has also been lodged separately. A site location plan is enclosed at Appendix 1. The Former Southam Cement Works site is a part brownfield part greenfield site and extends to a total of circa 105 hectares. It is identified as a Large Rural Brownfield site in the Adopted Core Strategy 2016 (Policy AS.11). Whilst the site lies to the north of Southam (a Main Rural Centre) and to the south of Long Itchington (a Category A Local Service Village). The Reg 18 SWLP identifies Policy AS.11 as a Part 1 policy that will be reviewed, with either an identical policy, adjusted or new policy. The site has an active operational life of 20-25 years, rather than continue with Policy AS.11 as a ‘redundant land’ policy, in our view the SWLP should progress a new ‘live’ policy that facilitates the phased release of the site to encourage organic employment growth ahead of the release of the operational land. The provision of residential accommodation in this context would enable a mixed-use co-ordinated scheme over the plan period. The opportunity for an employment led Garden Village on the site and surrounding land is considered further below and in ‘the Opportunity’ note enclosed at Appendix 1. The SWLP Reg 18 consultation includes a number of questions. We provide detailed responses in respect of the relevant questions below. Proposed Approach to Online Form and Consultation Portal We have completed the Online Forms on the SWLP Consultation Portal for the site as requested by the Council. However the Online Form is overly restrictive. For questions which require an option to be chosen, there is not always an opportunity to pick neither option. Therefore, we have artificially selected options in order to register an interest to comment, whilst cancelling out these choices, our detailed comments are set out in the covering letter below and we request that that they are considered by Officer’s in full, as well as the enclosures listed. Whilst we appreciate the Council’s desire to gather quantitative data, we would suggest that there needs to be the option to provide additional commentary otherwise the results of the consultation are notrepresentative.

In addition to comments previously made the Council wishes to raise an issue with regard to a number of ‘call for sites’ submissions it is aware that were submitted in response to the previous consultation. These related to sites around Hockley Heath. Hockley Heath is a small settlement located within Solihull, but essentially closely bounded on three sides by the boundary with Stratford upon Avon. Within Solihull’s emerging plan (which is currently at examination), the settlement is identified in the spatial strategy as a rural settlement identified for limited expansion. To date the Inspectors have not raised any fundamental issues with the spatial strategy and the Council is expecting it will form part of the adopted plan. In accordance with the spatial strategy an allocation (in Solihull’s plan) to accommodate some 100 dwellings has been made for the settlement and it is considered that this fulfils the ability of the settlement to accommodate limited expansion. It is noted that the diagram supporting the dispersed growth option does not indicate the Hockley Heath area as an indicative location that may feature in this option. Nor is the village listed (on page 71) in the settlements considered under this option. The Council supports this position. To identify the settlement as a location for growth to take place in South Warwickshire would be considered to run contrary to the spatial strategy in Solihull’s plan. It would have a detrimental impact on the character of the village and would not be supported by the necessary infrastructure, a factor complicated by not being within the same LPA. I hope these comments are helpful and we look forward to continuing with joint working.

Q-S2: As set out at Paragraph 124 of the NPPF, planning policies should support development that makes efficient use of land. Moreover Paragraph 127 states that area-based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places. Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site. We would suggest that there is a need to understand existing housing need in the first instance, the ability for that need to be accommodated in the plan area and the policy response needed to meet that need. The use of design codes is appropriate, however we would caution against an approach that relies on numerous Design Codes needing to be prepared at Part 2 as it could delay delivery. Q-S3.2: The NPPF clearly identifies at Paragraph 120 that planning policies should give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land. Paragraph 141 highlights that before concluding that exceptional circumstances exist to justify Green Belt boundaries, consideration should be given as to whether the strategy inter alia makes as much use as possible of suitable brownfield sites and underutilised land. The test is therefore one of ‘suitability’. The prioritisation of brownfield redevelopment in line with the identified growth strategy, where it can be proven the site is in a sustainable location, or when the development can show that it would have a positive impact on the sustainability of the area is a logical approach. Again, we would suggest that there is a need to understand existing housing and employment need in the first instance to then understand what the appropriate policy response is to meet that need. In this instance there is an opportunity to review the approach to AS.11 Large Rural Brownfield Sites to move from a ‘redundant land’ policy, to a new ‘live’ policy that facilitates the phased release of brownfield site’s such as the Former Southam Cement Work. This has the opportunity for these sites to transition to other uses, contribute to growth, rehabilitate degraded land, facilitate improved connections and achieve growth in an organic way. Q-S7.2: All of the above questions relate to growth strategy and where new development should be directed. Growth Options 1 and 2 rely on the creation of new settlements (6,000 new dwellings or more) linked to the achievement of new or reopened rail corridors. New settlements have long lead in periods, often rely on complex land assembly and in this instance are reliant on notable infrastructure funding and delivery outside of the control of the districts. Whilst the plan period to 2050 provides time for any such settlement(s) to come forward, they are unlikely to contribute to growth until towards the end of the plan period. There is a pressing need for delivery of housing and economic growth now therefore we would caution against an approach that seeks to rely on meeting a substantial proportion of housing need through standalone settlements. In our view to meet a range of housing and economic needs and provide a sufficient and deliverable supply of housing land, a mixture of the different options would be preferable. Southam is cited as a settlement/location that may feature within Growth Options 3, 4 and 5. As per Table 20 of the SWLP, the intention is to include a review of Policy AS.11 in Part 1 of the SWLP. This means either adopting an identical policy, adjusting or re -working the policy or creating a new policy on the same subject. As such, the development of the Former Southam Cement works site would be compatible with and supportive of a number of the above Growth Options and intention to review AS.11. A separate note has been prepared on ‘The Opportunity’ for an employment led Garden Village at the former South am Cement Works, enclosed at Appendix 1. This draws on the Garden City movement of the 20th century, and the history of the site, with the existing Model Village to the west constructed in phases in the early 20 th Century to house workers at the Southam Cement Works. The underlying concepts of the ‘garden village’ have been reimagined more recently with the ’15-Minute City’ or ’20-Minute Neighbourhood’. All relate to the creation of compact connected places where people can meet their everyday needs with in a short walk or cycle. This includes a range of local jobs within eas y commute. The core principles of the opportunity at the former Southam Cement Works includes: • A range of local jobs within easy commuting distance; • Mixed tenure homes, and housing types, that meet identified local need and affordability; • Beautifully designed homes with gardens, reflecting local character and materials. • Development that enhances the natural environment, maintaining and enhancing the existing green infrastructure network and wider opportunities for biodiversity net gain; • Prioritisation of low carbon and energy efficient technology with the aim of achieving a climate resilient development; • Supporting walkable recreation and shopping facilities; and • Improve connections with wider facilities in Long Itchington and Southam making walking, cycling and public transport the most attractive forms of transport. We would welcome the opportunity to meet with the Council to review the above, the opportunitie s for the site as per AS.11 Large Rural Brownfield Sites and the SWLP Reg intention to review this policy. Moreover, understand how the revised approach to AS11 could relate to Southam falling within the Core Opportunity Area where Q-E7.1 explores the potential for employment growth. In our view there is an opportunity for a policy approach that facilitates the phased redevelopment of the site and wider land holding for an employment led Garden Village that supports and intensifies employment and mixed use together with housing in a manner consistent with CEMEX’s long-term commitment to the site and the District as a long standing business and employer. We would suggest that a Masterplan, with phasing options, would be the vehicle by which to test the above Garden village principles. It would be useful to discuss the above proposition with Officers, the scope of the masterplan and the strategy for consultation and engagement. It would also be useful to discuss the relevant evidence base that should be prepared and how that might relate to that being assembled to support the local plan review and support consideration in the emerging SA.

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. I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. 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 feelit is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire We consider Option S3.2a is most appropriate for South Warwickshire. Reusing suitable brownfield land for new development can provide an effective use of land and reduces the need for development on undeveloped greenfield sites. National policy places emphasis on strategic policies setting out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously developed or ‘brownfield’ land. Currently, redevelopment proposals for previously developed land in the open countryside in Stratford-on-Avon District would either be assessed against Core Strategy Policy AS.10 ‘Countryside and Villages’ or Policy AS.11 ‘Large Rural Brownfield Sites’, depending on whether the site is to be considered ‘small scale’ or an ‘extensive’ previously developed site. Policy AS.11 ‘Large Rural Brownfields Sites’ supports the re-use and redevelopment of extensive previously developed sites in the countryside, outside the Green Belt, where it can be demonstrated that the proposal is in compliance with the following criteria: a) The extent to which the nature of the proposed development would be in the national or local interest. b) Whether the form and scale of the proposed development could reasonably be provided elsewhere in the District in a manner that is consistent with the overall development strategy set out in this Plan. c) The extent to which the nature of the proposed development would be beneficial compared with the current use and condition of the site. d) The scale and nature of impacts, including visual, noise and light, on the character of the local area and local communities. e) The extent to which features that are statutorily protected or of local importance are affected and any impact on them can be mitigated. f) The scope to minimise the need to travel and promote the use of transport other than the private car. g) The absence of development on any area of the site liable to flood risk.’ If sites are to be regarded as small scale, redevelopment proposals would be assessed against Policy AS.10 ‘Countryside and Villages’. This policy applies to all parts of the District apart from those which lie within the Built Up Area Boundaries defined for Stratford-upon-Avon and the Main Rural Centres and land covered by Policy AS.11 Large Rural Brownfield Sites. Policy AS.10 includes a ‘residential’ section which considers which forms of development in the countryside are acceptable in principle. There are nine such criteria included. However, none are applicable to small-scale housing schemes on previously developed sites adjoining or close to defined Built-Up Area Boundaries of settlements. There is an internal tension within Policy AS.10 between an underlying purpose in terms of promoting development on previously developed land in sustainable locations and the containment of housing within settlements. It is considered that Option S3.2a, which seeks to prioritise brownfield development if it can be proven that the development is in a sustainable location, would resolve the current tension within Policy AS.10. Land off Waterloo Road, Bidford-on-Avon comprises previously developed land immediately to the north of Bidford-on-Avon, separated from the defined Built-up Area Boundary by a watercourse (known as Small Brook) and the Green Acres Travellers Site to the south. The location is considered geographically sustainable by reason of its accessibility for pedestrians via a dedicated footpath on Waterloo Road that leads to the site entrance. In addition, the nearest bus stop to the site is located approximately 400 metres (within walking distance) to the south on Waterloo Road. Services from this stop operate regularly, with hourly services (buses 247 and 247s) to Redditch, Alcester and Evesham. The Site is not land of high environmental value, nor would redevelopment of this site lead to the loss of agricultural land or result in any encroachment into the countryside as the proposals would involve the redevelopment of the available brownfield land within the site. The delivery of this site for approximately 10 dwellings would not put undue pressure on key elements of infrastructure in Bidford-on-Avon, including Bidford-on-Avon Primary School. The scale of development is appropriate to Bidford-on-Avon, due to its position within the settlement hierarchy as a Main Rural Centre. Overall, it is considered that the re-development of the promotion site would constitute sustainable development by reason of: • Reducing the need for development on undeveloped greenfield sites • It would not lead to the loss of agricultural land or result in any encroachment into the countryside • It is well connected to the built-up area of Bidford-on-Avon and has good accessibility for pedestrians via a dedicated footpath on Waterloo Road that leads to the site entrance • It would minimise the need to travel and promote the use of transport other than the private car, particularly due to the close proximity to employment opportunities available within Bidford-on-Avon in addition to its good accessibility to bus services Therefore, Option S3.2a, which seeks to prioritise brownfield development if it can be proven that the development is in a sustainable location or would increase the sustainability of the area, is supported. Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: It is considered that none of these Spatial Growth Options should be selected exclusively. A portfolio approach which seeks to prioritise settlements which benefit from a combination of the above growth options and principles, would be more conducive to sustainable growth. For example, the only second-tier settlement in Stratford-on-Avon District which benefits from a railway station is Henley-in-Arden, which lies within the West Midlands Green Belt. Consequently, this growth option would require the release of Green Belt land. Equally, dispersing growth (Option 5) would not help encourage sustainable travel, as many of the new homes in smaller, rural settlements and villages would inevitably be poorly connected by public transport, and long distances from the facilities needed for day-to-day life. A portfolio approach would follow the advice in the Framework, which expects development to be focussed in the most sustainable locations in terms of availability of shops, facilities and services, as well as access by modes of transport other than the private car. In addition, this approach would allow development to be distributed over a range of settlements rather than in single settlements in order to ensure their vitality and viability in accordance with the principles of sustainable development. Bidford-on-Avon is clearly a sustainable location to accommodate additional housing growth. As set out previously under Q-S4.1, Bidford-on-Avon is categorised as a ‘Main Rural Centre’ in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy and is one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-on-Avon District. Bidford-on-Avon is a large village which contains a range of local services and facilities, including a supermarket, convenience store, primary school, pharmacy, restaurants and public houses. There is an established industrial estate, which supports a wide range of jobs, to the north of Bidford-on-Avon off Waterloo Road. The promotion site would be well connected to the built-up area of Bidford-on-Avon and would constitute sustainable development. It has good accessibility for pedestrians via a dedicated footpath on Waterloo Road that leads to the site entrance. In addition, the nearest bus stop to the site is located approximately 400 metres (within walking distance) to the south on Waterloo Road. Services from this stop operate regularly, with hourly services (buses 247 and 247s) to Redditch, Alcester and Evesham. A portfolio approach to growth in South Warwickshire would ensure that housing is focused in existing settlements, such as Bidford-on-Avon, where there are existing employment opportunities, local services and facilities, and where there is a need to ensure vitality. It is considered that this growth option would be consistent with national planning policy and basic sustainability principles and should be supported as the Plan progresses.

Q-S2 Intensification 9. Intensification is a way to optimise brownfield land and realise its effectiveness. However, HLM consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 10. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided. Q-S4.1: Growth of Existing Settlements 16. Yes, growth of existing settlements in South Warwickshire (and on the edge of South Warwickshire) is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure are all generated within the existing settlements. Those needs are best met sustainably adjacent to the settlements, rather than in new settlements. Q-S7.2: Refined Spatial Growth Options 18. HLM consider a mixture of options will be required to best deliver the growth needs of South Warwickshire for the reasons as set out below. 19. Firstly, the results of the high level testing of the five growth options in the supporting Sustainability Appraisal demonstrates that the options perform differently in different areas, with no one option standing out as the best performing option across all areas. 20. Secondly, it is important to remember that the assessment set out in the SA is provided at a high level, subject to several caveats, and without consideration of mitigation or deliverability. Options which score less favourably in the SA could therefore actually deliver more sustainable growth on closer examination. 21. Finally, given the significant level of growth the SWLP will need to accommodate (see response to Issues H1 and H4 below) this is unlikely to be able to be met sustainably through a single growth strategy. 22. HLM support the inclusion of the urban area of Warwick & Leamington in each of the options. Q-S10: Other Development Strategy Issues 23. More generally, south of Warwick and Leamington was identified in the adopted Warwick Local Plan (2017) as one of the most appropriate locations for strategic growth based on the availability of suitable sites to deliver sustainable urban extensions, lack of overriding constraints, being outside of the Green Belt and the opportunity to support the existing facilities within the towns. Further growth in this area would be consistent with the achievement of sustainable development as set out in national policy. 24. HLM have set out an Emerging Vision for its site which shows how development could help achieve the five overarching principles of the Plan. This includes a commitment to designing the development to drive down emissions, and provide new and sustainable nearby services and facilities. This Vision sees the provision of a substantial extension of Tachbrook Country Park to provide a permanent buffer between Bishop’s Tachbrook village and the urban area. HLM would be happy to meet to discuss this further with the Councils.

System will neither let me change my password nor have a new account. Section 10 I want to know why you are thinking of changing the boundaries north of Leamington and South of Kenilworth when the planning inspector has ruled that the are OK relatively recently.

My feelings are: Please protect our precious wildlife. Do not build next to SSSI areas Do not build next to protected woodlands which will be ruined by increased human activity and footfall. Do not build in greenbelt. Use brownfield sites, but not greenbelt, which has been instilled for very good reason. Do not use our neighbourhood to provide buildings site Birmingham overflow. This is not right and will ruin our beautiful landscape. The wildscapes are a good idea, however, wild life must be connected and not isolated. 30% is not enough, please increase it.

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. I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. 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.

Drayton Manor Farms Ltd responded to the call for sites in June 2021 with SWLP Ref ID 21 “Drayton Manor Farm, Alcester Road, Stratford-upon-Avon CV37 9RQ”, Information to support SWDP Ref ID 21 is: It lies adjacent to the Built-up-Area Boundary of Stratford-upon-Avon. The land has no particular planning designation and is accessed via the A46 and the public road Drayton Manor Drive. To the east is land identified in the Core Strategy as a large-scale employment site (Policy SUA.2; IM Properties ref 19/01402/OUT, granted 12 Dec 2019). Construction will soon begin on the construction of a new roundabout at the junction with the A46. These highway works will improve accessibility to Stratford-upon-Avon by driving, cycling and public transport. The approved works include: i. new roundabout at the A46/Drayton Manor Drive junction; ii. pedestrian/cycle link between SUA.2 and Wildmoor roundabout; iii. pedestrian crossing facilities at Wildmoor roundabout; iv. extension of the X19 bus service into SUA.2 and an associated financial contribution. To the west is a business park measuring 6.9 hectares and including 24 buildings with a combined floorspace of 20,371m2. It currently sustains about 160 jobs and 10 businesses. It has its own electricity substation and emergency generator, weighbridge, self-contained water and foul drainage systems and storage tanks. Also to the west is a 50 mega watt solar farm, within the same ownership. There is scope for this proposed allocation to rely heavily upon renewable energy.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire We consider Option S3.2a is most appropriate for South Warwickshire. Reusing suitable brownfield land for new development can provide an effective use of land and reduces the need for development on undeveloped greenfield sites. National policy places emphasis on strategic policies setting out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously developed or ‘brownfield’ land. Currently, redevelopment proposals for previously developed land in the open countryside in Stratford-on-Avon District would either be assessed against Core Strategy Policy AS.10 ‘Countryside and Villages’ or Policy AS.11 ‘Large Rural Brownfield Sites’, depending on whether the site is to be considered ‘small scale’ or an ‘extensive’ previously developed site. Policy AS.11 ‘Large Rural Brownfields Sites’ supports the re-use and redevelopment of extensive previously developed sites in the countryside, outside the Green Belt, where it can be demonstrated that the proposal is in compliance with the following criteria: a) The extent to which the nature of the proposed development would be in the national or local interest. b) Whether the form and scale of the proposed development could reasonably be provided elsewhere in the District in a manner that is consistent with the overall development strategy set out in this Plan. c) The extent to which the nature of the proposed development would be beneficial compared with the current use and condition of the site. d) The scale and nature of impacts, including visual, noise and light, on the character of the local area and local communities. e) The extent to which features that are statutorily protected or of local importance are affected and any impact on them can be mitigated. f) The scope to minimise the need to travel and promote the use of transport other than the private car. g) The absence of development on any area of the site liable to flood risk.’ If sites are to be regarded as small scale, redevelopment proposals would be assessed against Policy AS.10 ‘Countryside and Villages’. This policy applies to all parts of the District apart from those which lie within the Built Up Area Boundaries defined for Stratford-upon-Avon and the Main Rural Centres and land covered by Policy AS.11 Large Rural Brownfield Sites. Policy AS.10 includes a ‘residential’ section which considers which forms of development in the countryside are acceptable in principle. There are nine such criteria included. However, none are applicable to small-scale housing schemes on previously developed sites adjoining or close to defined Built-Up Area Boundaries of settlements. There is an internal tension within Policy AS.10 between an underlying purpose in terms of promoting development on previously developed land in sustainable locations and the containment of housing within settlements. It is considered that Option S3.2a, which seeks to prioritise brownfield development if it can be proven that the development is in a sustainable location, would resolve the current tension within Policy AS.10. Land off Wheelwright Way, Wellesbourne comprises previously developed land adjoining the Built-up Area Boundary of Wellesbourne and adjoining existing residential development. The Site is not land of high environmental value, nor would redevelopment of this site lead to the loss of agricultural land or result in any encroachment into the countryside as it is contained by the adjoining residential development to the east, Wellesbourne Mountford Aerodrome to the north and west, and Loxley Road to the south. The delivery of this site for approximately 20 dwellings would not put undue pressure on key elements of infrastructure in Wellesbourne, including Wellesbourne Primary School. The scale of development is appropriate to Wellesbourne, due to its position within the settlement hierarchy as a Main Rural Centre. The promotion site would be well connected to the built-up area of Wellesbourne and it is considered that the new homes at land off Wheelwright Way would respond well to the 20-minute neighbourhood concept, owing to the close proximity of the site to Wellesbourne’s services and facilities. The Site is within 800 metres (a 10-minute walk) of the Sainsbury’s supermarket located on Loxley Road. Indeed, the Site was initially included as part of the Outline proposals for the residential development at Wellesbourne Distribution Park (LPA Ref. 13/00510/OUT). When the planning application was submitted, no objections were received from Landscape Officers regarding the landscape and visual impact of the proposals. However, the applicant decided to withdraw this small parcel of the site as expediency towards the consent of the remainder of the site, because of a then, unresolved issue relating to aviation matters. These written representations are accompanied by a Physical Safeguarding Assessment of Wellesbourne Mountford Aerodrome (Appendix 3) which demonstrates that a residential development at the site would not infringe the prescribed transitional, takeoff climb and approach surfaces for light aircraft arriving or departing from the aerodrome. Therefore, there are no aerodrome safeguarding or public safety related reasons to withhold an allocation or consent for a residential development at this site. It is also understood that there are preliminary proposals to replace the current north/south runway at Wellesbourne Mountford Aerodrome with a new runway; to be located further to the west with a minor realignment to its orientation away from the promotion site at land off Wheelwright Way, Wellesbourne. If these changes occur, there will be no impact or aviation related constraint on any future proposals to redevelop the land off Wheelwright Way for residential purposes. Overall, it is considered that the re-development of the promotion site would constitute sustainable development by reason of: • Reducing the need for development on undeveloped greenfield sites • It would not lead to the loss of agricultural land or result in any encroachment into the countryside • It is well connected to the built-up area of Wellesbourne and immediately adjoinsexisting residential development • It would respond well to the 20-minute neighbourhood concept, owing to the close proximity of the site to Wellesbourne’s services and facilities • It would minimise the need to travel and promote the use of transport other than the private car, particularly due to the employment opportunities available within Wellesbourne Therefore, Option S3.2a, which seeks to prioritise brownfield development if it can be proven that the development is in a sustainable location or would increase the sustainability of the area, is supported. Issue S7: Refined Spatial Growth Options It is considered that none of these Spatial Growth Options should be selected exclusively. A portfolio approach which seeks to prioritise settlements which benefit from a combination of the above growth options and principles, would be more conducive to sustainable growth. For example, the only second-tier settlement in Stratford-on-Avon District which benefits from a railway station is Henley-in-Arden, which lies within the West Midlands Green Belt. Consequently, this growth option would require the release of Green Belt land. Equally, dispersing growth (Option 5) would not help encourage sustainable travel, as many of the new homes in smaller, rural settlements and villages would inevitably be poorly connected by public transport, and long distances from the facilities needed for day-to-day life. A portfolio approach would follow the advice in the Framework, which expects development to be focused in the most sustainable locations in terms of availability of shops, facilities and services, as well as access by modes of transport other than the private car. In addition, this approach would allow development to be distributed over a range of settlements rather than in single settlements in order to ensure their vitality and viability in accordance with the principles of sustainable development. Wellesbourne is clearly a sustainable location to accommodate additional housing growth. As set out previously under Q-S4.1, Wellesbourne is categorised as a ‘Main Rural Centre’ in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy and is one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-on-Avon District. Wellesbourne is a large village which contains a range of local services and facilities, including a supermarket, convenience store, primary school, a sports and community centre, medical centres, pharmacy, restaurants and public houses. There is an established employment area, which provides a range of jobs, to the north west of Wellesbourne adjacent to Wellesbourne Mountford Aerodrome. The promotion site would be well connected to the built-up area of Wellesbourne and would constitute sustainable development. Indeed, it is considered that the new homes at land off Wheelwright Way, Wellesbourne will respond to the 20-minute neighbourhood concept, owing to the close proximity of the site to Wellesbourne’s services and facilities. A portfolio approach to growth in South Warwickshire would ensure that housing is focused in existing settlements, such as Wellesbourne, where there are existing employment opportunities, local services and facilities, and where there is a need to ensure vitality. It is considered that this growth option would be consistent with national planning policy and basic sustainability principles and should be supported as the Plan progresses.

I would like to object to the building on green belt fields in North Leamington( Old Milverton and Blackdown) for the following reasons: Agricultural land should be preserved for the sake of food security. The footpaths offer recreational and health benefits for the residents of Leamington Spa. It protects the identities of Leamington and Kenilworth by preventing them to merge into one another. It assists in urban regeneration, by encouraging the use of brown field sites in line with the 'Brownfield First' pledge.

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. I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. 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

Please find below our views on the South Warwickshire Local Plan, in particular, the Green Belt north of Leamington: The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: • check the unrestricted sprawl of large built-up areas • prevent neighbouring towns merging into one another • assist in safeguarding the countryside from encroachment • preserve the setting and special character of historic towns • assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The Green Belt around North Leamington is a valued open space. We agree with surveys that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health. It is easily accessible on foot from North Leamington so many people, including us, can access the public rights of way across the fields. Use of these footpaths increased markedly during lockdown and these high levels of use continue today. The agricultural land continues to provide rural employment. Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever. The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. 1. Recent Government policy has stated that farming and food production make an important contribution to sustainable development. 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. The proposals would lead to a sprawling northwards of Leamington Spa and would ruin the distinct identity of the towns of Leamington Spa and Kenilworth Developing the North Leamington Green Belt would significantly reduce the belt of land that separates Kenilworth from Leamington, particularly in view of the Thickthorn housing development now underway and other recent housing and commercial developments in the area. The proximity of HS2 developments in neighbouring parishes is also strongly felt. Despite this, numerous other sites along the A452 have been put forward in the Call for Sites. Once land is removed from the Green Belt for development this cannot be undone and a precedent is set which makes it easier for adjoining swathes of land to be built on. Building more new houses on the outskirts of Leamington will exacerbate the current high levels of traffic congestion and air pollution, which has come with the new housing developments south of the town. The original layout of the town and the subsequent development in the 19th and 20th centuries precludes the construction of major new cross town access routes. The joint Green Belt study of 2015 highlights the important contribution to preventing the merging of Leamington, Kenilworth and Coventry that this piece of the countryside (Broad Area 3) makes by preventing urban sprawl, safeguarding the countryside and preserving the special character of these historic towns. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” . It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area”. This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. It is not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The Green Belt around North Leamington is one of these "genuine constraints". It skews development away from providing affordable housing in the areas where people work. The Government has also made a “brownfield first” pledge which should inform the way that the District Councils respond to unmet housing need in other authorities. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations such as Coventry are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas such as Leamington where developers can make a bigger profit. The process is flawed because all five options presume Green Belt development without acknowledging the significant constraints involved. The Issues and Options consultation puts forward five “spatial growth options”. All of these would involve development of some areas of Warwickshire’s Green Belt, and all of them suggest North Leamington Green Belt as an area of ‘significant urban extension’. This is in line with the outcomes from a series o spatial growth workshops which revealed a preference to promote development at scale within the Green Belt. However the premise of these workshops is grossly flawed. The proposition that Green Belt serves no legitimate function and can be ‘switched off’ as an academic exercise flies in the face of the significant contributions that Warwick District Council and Stratford District Council have themselves noted that Green Belt designation makes. The Green Belt puts major restrictions – for good reason – on what can be built where. The workshops did explore growth options where Green Belt development was not permitted. However none of these feature in the current five spatial growth options. This is contrary to recent Government announcements, the 2015 greenbelt review and the 2017 response by the Planning Inspector. The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. We think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development. Finally, we would draw attention to the fact that the statistic used in the consultation about support for Green Belt development is highly misleading and inaccurate. The document says that 54% of respondents support the exploration of Green Belt growth opportunities, without mentioning that 45% of all respondents were developers, land owners and businesses who clearly have a vested interest in support of such developments. In summary, we believe that it is unnecessary and inappropriate to develop the Green Belt north of Leamington because: • it is not in line with current government policy • the Green Belt north of Leamington delivers all 5 of the stated purposes of Green Belt land • the land is high quality agricultural land which should be used to safeguard and promote food security • there are alternatives to development of the Green Belt north of Leamington which have been explored by the planners but are not presented as options in the consultation document. We trust that you will take account of all the above persuasive arguments and ensure that the Green Belt north of Leamington is preserved for current and future residents.