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

Q-S9: Hayfield consider that in identifying the appropriate Spatial Strategy for South Warwickshire, it will become apparent which settlement boundaries will require review. For the reasons outlined above in relation to Issue S7, it is Hayfield’s strong view that Growth Option 5 should be pursued, to support the vitality of South Warwickshire’s rural communities. The Part 1 SWLP should therefore identify the relevant growth villages which will require a boundary review through the Part 2 SWLP, including Quinton. To prevent delay to the delivery of housing within sustainable growth villages such as Quinton, Hayfield consider that the Part 2 SWLP should be progressed without delay. A mechanism should be secured within the Part 1 SWLP, to trigger the preparation of the Part 2 document immediately following the adoption of the Part 1 document. The submission of suitable deliverable sites through this consultation and the Call for Sites exercises, will facilitate the early identification of sites within the Part 2 SWLP, and will support the review of settlement boundaries, as well as the consideration of sites through the planning application process.

Issue - S1a: Support. Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. Using this joint evidence base would appear to be a sensible way forward to develop to joint local nature recovery strategy.

500 HOUSES!!!! another concrete jungle!! Appalling! Wootton Wawen is a beautiful historical green belt village and I for one have benefited in many ways from living in this picturesque beauty spot, as, I'm sure, I can speak for many other residents. The village would certainly suffer if the above proposal was to go ahead. We have beautiful countryside where many clubs enjoy visiting whether it be tourist, cycling, walking or other outdoor activities. Our public footpaths would no longer benefit from the surrounding beauty of the green fields with crops and livestock. Who would want to enjoy any of the above that's full of concrete??? Our lanes are already busy, which means that additional properties (500) would incur more traffic (average 2 cars per property, totalling an average of 1000 extra vehicles). How on earth can the village cope with this multitude of extra traffic. The lanes are bendy, with blind corners especially down Alcester Road and Wawensmere Road which is dangerous enough for walkers, so, lanes/roads would have to be widened, destroying the verges, hedgerows, and trees, which would then affect the beautiful wildlife that we are fortunate to have. The range of beautiful birds would disappear as the vegetation would be destroyed. It is known that people suffering with mental health, benefit from the rural countryside villages, and have less health issues than those who live in built up areas. Keeping our village rural, plays an important part for visitors who suffer with depression or other mental health issues. How can we possible destroy our rural village and benefit ?? Surely there are plenty of empty buildings in the towns that have been empty for years especially in Stratford town centre which to me, seems to becoming a ghost town. Surely by turning these into homes would be more appropriate than destroying 'green belt' area. "PLEASE KEEP WOOTTON WAWEN AS IT IS, A BEAUTIFUL HISTORICAL COUNTRYSIDE VILLAGE THAT WE'RE ALL PROUD OF".

I would like to express my concerns as to the possibility of using Green Belt Land in the areas surrounding Milverton & Blackdown for a potential housing development. I think the Green Belt land is very important to the wellbeing of the local community and strongly urge you to re-consider and look at 'brownfield' land first to find solutions. The Green Belt around the North of Leamington fulfils the purpose of Green Belt land. The five stated purposes of Green Belt land are to: 1) Check the unrestricted sprawl of large built-up areas 2) Prevent neighbouring towns merging into one another 3) Assist in safeguarding the countryside from encroachment 4) Preserve the setting and special character of historic towns 5) Assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The Green Belt land around the North of Leamington is highly valued and a truly lovely open space. As a local resident I know how vital/valuable it is to myself and lots of others for both their physical and mental health. It has stunning views and is a godsend to the local community ...especially in these changing times i.e.. Covid Pandemic/lockdowns. The land has lots of easily accessible public right of way footpaths across the fields. The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. This agricultural land provides employment and the mixed arable, grazing and wildlife refuge all helps to maintain the wonderful atmosphere of the village known as 'Old Milverton' ...which is a very short distance from the town of Leamington Spa, but it has a totally rural feel because of this highly valuable Green Belt land surrounding it. One of the most important reasons for a Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban lane. Hence, the "brownfield first" pledge. Warwick District Council should not be looking at Green Belt land to deliver housing. The Government has recently made it clear in a letter from the Secretary of State that local planning authorities such as Warwick District Council are not expected to review the Green Belt to deliver housing. Development to the Green Belt to the north of Leamington Spa would hugely reduce land that separates Kenilworth from Leamington Spa. A similar proposal to this was rejected less than 6 years ago. In fact, the planning inspector's response was the Local Plan for Warwick District stated a need to maintain the separate identity of villages such as Cubbington and to avoid reductions in the gap of land to Kenilworth. These are all still very valid reasons not to consider the use of this local Green Belt area. PLEASE PLEASE PLEASE re-consider

If you have any further comments, please write them here.: It is time to complete my article: " The trashing of Kenilworth", long overdue. As a town resident of nearly 50 years, it has been a very sad experience to see such a decline. watch the town's decline

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.

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.

Please acknowledge receipt of this mail and please find below our comments regarding potential developments that affect us and our neighbours. We have lived at [Redacted Text] for 19 years. My family and I chose to live here because: ·it was QUIET, the 6th form school was empty most evenings and weekends and so was silent at those times, ·it was relatively SAFE, ·had EASY ACCESS to Warwick Road and to the A46 via Leek Wootton, and to the town centre and to roads going to Solihull, ·had WALKING access along Rouncil Lane and via paths between houses along Rounds Hill to many walks including on the golf course and out towards Bausale and to Kenilworth Castle. ·we believed our house would be a good investment and hold it’s value in the housing market. We are now aware of at least 2 plans for additional housing that are in our immediate area, namely the redevelopment of the Kenilworth 6th form school site and the plans for land between the A46 and Warwick road and the land west of Rouncil Lane and Rounds Hill. These are potentially of significant size in terms of numbers of new homes, and as such have the potential if they were to go through, to change the character of the area in which we live. I and my family have the following concerns regarding any new developments in our area. The junction between Rouncil Lane and Warwick Road, and at Warwick Road by the Texaco petrol station would become overloaded during peak periods. These junctions are already an issue for local residents wishing to commute in and out of our area in rush hours, and they would be significantly worse after and new developments. The roads that abut the A46/A452 roundabout will become car parks for people wishing to enter or leave Kenilworth at rush hours. Walking access to country walks should not be allowed to be negatively impacted by new developments. Any new developments that are adjacent to the A46 should be planned with new and direct vehicular access to the A46 by way of new junction/s to avoid adding all of the new traffic loading to the existing routes. With regard to the development on the Kenilworth 6th form site: ·We would be happy for new homes that are to be situated near ours to be of similar size and value. ·We would not be happy if electricity substations or playing areas were to be situated adjacent to our plot as these could be noisy and unpleasant, and could impact the value of our home. Rather, we believe such items should be located nearer to the centre of the development so as to avoid impact on existing residents.

Issue S2 - Intensification Q-S2: Please select all options which are appropriate for South Warwickshire Rosconn Strategic Land clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Rosconn Strategic Land clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Issue S3: Using Brownfield Land for Development Q-S3.2: Please select the option which is most appropriate for South Warwickshire Rosconn Strategic Land clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Issue S4 – Growth of Existing Settlements Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Rosconn Strategic Land clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Rosconn Strategic Land clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Rosconn Strategic Land clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Issue S5 The Potential for New Settlement(s) Q-S5.2: Do you think new settlements should be part of the overall strategy? Rosconn Strategic Land clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Issue S8: Small scale development outside of the chosen spatial growth option Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Rosconn Strategic Land clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: •It may be too simple to adapt and address the specific and changing needs andrequirements of settlements of different sizes •It may result in the housing threshold being met within the first five years of the Planperiod leaving no opportunity for further organic growth for the remainder of the Planperiod, potentially another 20 years, even if further housing needs are later identified •It may artificially reduce the size of the most appropriate development sites, or resultin under-development. For example the best site to meet development needs mayaccommodate 15 houses, but with a threshold set at 10 houses it may either beartificially reduced or under-developed. •If a threshold is too low it may result in reduced provision of affordable housing,particularly for sites with high infrastructure costs •It may result in buildings and sites being left vacant if thresholds are met beforesuitable sites become available. An example would be a small commercial yard inthe centre of a settlement which is active at the beginning of the Plan period.Planning permission is granted for the development of a site adjacent to thesettlement which uses the full threshold allowance. The commercial yard thenbecomes vacant and no other commercial use can be found. Policies must then besufficiently flexible to allow further residential development to prevent the commercialsite lying vacant. Issue S8: Small scale development outside of the chosen spatial growth option 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 None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Issue S9: Settlement Boundaries and Infill Development Q-S9: Please select the option which is most appropriate for South Warwickshire Rosconn Strategic Land clients would choose 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. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Rosconn Strategic Land clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.

Issue I5 Green and Blue Corridors Q-S1 – Option S1a We consider that the SWLP should identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. However, this should be based upon proportionate evidence, which must be up to date. The SWLP refers to the Warwickshire Coventry and Solihull Sub regional green infrastructure study being used to inform policies, however this study dates back to 2013, and is therefore some 10 years old. This should be updated if it is to be used for the purposes of policy making, and included in the forthcoming suite of additional evidence base documents which can be commented upon as part of the plan making process in Stratford and Warwick. Issue S2: Intensification Please select all options appropriate Option S2c – Do not have a policy which encourages intensification. Each site should be considered on its own merits to take account of site-specific constraints and opportunities. A blanket approach to a policy with an ‘in principle ‘support for intensification or even the identification of sites which are considered to be particularly suitable could be counterproductive. Whilst it is acknowledged that the current Framework promotes the effective use of land in meeting the needs for homes, this should not be at the expense of healthy living spaces, or, as advised in footnote 47, “except where this would conflict with other policies in the Framework.” Any proposed intensification, per se could run contrary to the achievement of “well-designed or beautiful places” advocated by the Framework, which places great emphasis on “the creation of high quality, beautiful and sustainable buildings and places”. Furthermore, we are concerned that higher anticipated yields from such sites resulting from an intensification policy approach could result in the allocation of fewer sustainable green field sites – which could ultimately result in failure of the plan to deliver its requirement over the plan period because of the reliance on the yield from the intensification of the site, which may, in due course not be supported due to adverse impact on living conditions for future occupiers or character/appearance reasons and so on. Issue S3 Using Brownfield Land for development Q-S3.1-Option S3.2c We do not consider that a policy should be included in the SWLP to prioritise the use of brownfield land for development. There is no such policy imperative set out within the NPPF, and as result were the SWLP to prioritise brownfield land over greenfield development it would be inconsistent with national policy and fail the tests of soundness. By way of context, it is important to note that prior to the publication of the NPPF in 2012 the concept of sustainable development was largely based upon the delivery of previously developed land, with an express sequential approach set out in PPG3 (latterly PPS3) and PPG1 (latterly PPS1). This sequential approach was specifically removed from national policy, and a more nuanced approach to sustainable development set out. There is no indication that a sequential approach is to be brought back in, despite the various revisions to the NPPF which have been published since 2012. This is because utilising brownfield land does not automatically render a proposal sustainable; and to prioritise brownfield land would be to bring forward development that does not meet the three pillars of sustainability and potentially unbalance plan strategy and plan delivery, since development would only be brought forward where brownfield land exists, not where the plan making process determined development should be. Policy can make clear that the emphasis should be on utilising brownfield land for development, but this must not be expressed as a sequential approach nor applied as such through the development management function. Issue S4: Growth of existing settlements Q-S4.2: Yes, we agree that some of the existing settlements should be part of the overall strategy, particularly Southam. The SA has explored a number of alternative options for growth at existing settlements. The importance of considering the potential for growth around the edges of existing settlements is acknowledged. The growth of all existing settlements (proportionate to their size) could also assist the council to secure benefits associated with the 20-minute neighbourhood principle – the settlement analysis undertaken as part of the evidence base identifies settlements which are considered to be suitable for growth – based on connectivity, accessibility and density analysis. Issue S5: The potential for new settlements Q-S5.3 Do you think new settlements should be part of the overall strategy? No. We are of the view that new settlements should not be part of the overall strategy for the following reasons; • Due to the level of infrastructure required, new settlements can take years to come forward before housing can be delivered. This can seriously jeopordise the ability of the local plan to deliver both open market and affordable homes across the District for which there is a critical need. A study by Lichfields entitled “Start to Finish” (2016) highlights the problems associated with large scale development and compares them against delivery times for smaller developments. It highlights several examples of new settlements (2,000-3000 dwellings at Cambridge University). On average it took 10 years for the final schemes to be approved following allocation in the Local Plan (following outline and various reserved matters applications). The report did not go on to consider discharge of conditions applications/variations which actually may also delay the ability deliver the approved dwellings. This compares to smaller scale schemes which on average took 8 years. • The report states that large sites, which are not likely to deliver quickly, are also unlikely to be contributing to five year housing land supply calculations. The strategy should include small and medium sites which the Framework acknowledges can make an important contribution to meeting the housing requirement. • The reliance on new settlements within the strategy will also result in an inherently inflexible plan – which relies on the delivery of fewer but larger sites with multiple land owners. Coming to agreement over land value and sequencing of delivery are likely to be other factors which can delay the scheme which ultimately may result in developers having to contribute more to the infrastructure (drainage/highways etc) which will impact on viability, potentially at the expense of affordable housing provision. • It is for these reasons that several plans relying on large new settlements have failed – Uttlesford DC withdrew their plan due to the Inspector not being persuaded that evidence demonstrate the Garden Communities and overall spatial strategy had been justified. North Essex had similar problems with their proposed Garden Communities, which had to be removed from the Joint Local Plan before the Inspector found the Plan sound Issue S8: Small scale development outside of the chosen spatial growth option Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold development approach is appropriate, to allow more small-scale developments to come forward? Yes. We consider that it is appropriate for small scale development to come forward outside of the chosen strategy. This allows for unidentified development (windfall) to come forward over the plan period, which has the potential to support the vitality and viability of existing communities. New development in this circumstance should not be determined by a threshold. By setting a threshold, the suggestion would be that any specific settlement has some form of capacity or limit, and therefore any development exceeding the notional threshold would be inconsistent with the plan strategy. That cannot be the case. The ability for a settlement to accommodate new development will change over time (and noting that the plan period for the SWLP is extensive, to 2050), new development has the potential to increase the ability for a settlement to absorb growth (for example bringing with it new facilities, either on site or via the S106 regime). In any event development requirements should be expressed as a minimum with no ceiling or cap. Issue S9: Settlement Boundaries and infill development Q-S9 – It is our preference for Part 1 of the Plan to review and define all settlement boundaries across the combined district. This would achieve a consistent approach and allow smaller settlements to take more proportionate growth to enhance the vitality of rural communities.

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.

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.

Q-S1: Please select the option which is most appropriate for South Warwickshire As set out in the Vision Document (Appendix 2) prepared for Land at Warwick Road, Kenilworth, there is an existing watercourse (brook) located outside of, but immediately adjacent to, the south eastern corner of the Site. This provides an important blue corridor for wildlife and is proposed to be retained and protected within a suitable buffer of 8 metres to prevent disturbance to commuting species. Existing hedgerows and selective ‘gap’ planting will be retained and enhanced within the Site in order to preserve biodiversity both within the Site and connectivity across the wider landscape. SuDS will also form an integral part of the development’s green infrastructure, providing ecological benefits and habitat creation, as well as performing their principal function of controlling and managing the flow of surface water run-off during periods of heavy and persistent rainfall. The proposals will deliver a number of landscape benefits, including new Public Open Space, in addition to the creation of new habitats, such as wildflower grassland areas, native woody tree planting, wetland areas and ponds, providing opportunities for net gains in biodiversity. Therefore, the proposals for land at Warwick Road, Kenilworth demonstrate that green and blue infrastructure can be incorporated into development in many forms. It would be advantageous for additional evidence from the emerging Sub-Regional Green Infrastructure Strategy to be made available as soon as possible in order to inform the proposals for the Site. Therefore, Option S1a would be preferable, considering the production of a Local Nature Recovery Strategy will come after the SWLP Spatial Growth Strategy has been determined.

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. Any other comments: 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

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. Any other comments: 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

I wish to comment on the local plan. 1 It takes up vital agricultural land. 2 Many use this area for recreational purposes, especially country walks. 3 We always managed to preserve identities of Leamington and Kenilworth. Buildings should not encroach any further. Especially the character of Old Milverton must be retained and not ruiined by heavy traffic. 4 There would be a massive problem with the increase in transport to Leamington. Paticularly since it will be far to go to get to the main shopping area. This will result in more cars on the roads

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? Response: Yes As per our response to Q7.2, we consider a mechanism to deliver growth to the villages is appropriate. A threshold approach would be one mechanism by which this could be achieved. As set out at paragraph 68 of the NPPF, “small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” Identifying small sites can support the local economy by providing an opportunity for local housebuilding companies to secure land of a scale that is generally less attractive to the large national house builders. This helps to support the local economy within Warwickshire by providing local jobs and supporting the local supply chain thus delivering cumulative economic benefits. It is unclear at this stage as to the specific ‘threshold’ mechanism that may be applied. This could affect a range of settlements, in terms of service provision, population / size and location. Policy should allow for a range of sites to come forward, dependant on their characteristics and categorisation, thereby assisting in sustainable growth. There are successful examples of small sites coming forward at Fenny Compton, including Land East of Ridgeway on Christ Church’s land which provided 13 dwellings (reserved matters approved in November 2019 under 16/02284/REM and now complete). These sites can provide an important contribution towards meeting local housing need, including affordable provision. The landowner has identified a potential site to deliver further growth at Fenny Compton and has a track record of bringing land forward for development. 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? Response: A higher limit is appropriate It is difficult to specify a specific threshold / limit as the scale of development that is appropriate will depend on the location and also the growth strategy chosen. It is unclear at this stage as to the specific ‘threshold’ mechanism that may be applied. This approach could affect a range of settlements, in terms of service provision, population / size and location. Policy should allow for a range of sites to come forward, dependant on their characteristics and categorisation, thereby assisting in sustainable growth.The size limit will depend on the location and the site. Any development coming forward should seek to make efficient use of the site in accordance with paragraph 124 of the NPPF. It is noted that a threshold limit of greater than 10 dwellings would allow affordable homes to come forward in settlements that may fall outside of the main growth strategy. Q-S9: Please select the option which is most appropriate for South Warwickshire Response: Agree with Option S9a to save all existing settlement boundaries where these are already defined. There should be allowance for a consistent approach to be adopted across the Stratford-on-Avon and Warwick Districts and for boundaries to be reviewed to allow for future growth.

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? Response: Yes As per our response to Q7.2, we consider a mechanism to deliver growth to the villages is appropriate. A threshold approach would be one mechanism by which this could be achieved. As set out at paragraph 68 of the NPPF, “small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” Identifying small sites can support the local economy by providing an opportunity for local housebuilding companies to secure land of a scale that is generally less attractive to the large national house builders. This helps to support the local economy within Warwickshire by providing local jobs and supporting the local supply chain thus delivering cumulative economic benefits. It is unclear at this stage as to the specific ‘threshold’ mechanism that may be applied. This could affect a range of settlements, in terms of service provision, population / size and location. Policy should allow for a range of sites to come forward, dependant on their characteristics and categorisation, thereby assisting in sustainable growth. There are successful examples of small sites coming forward at Lower Quinton. The College secured outline planning permission for 44 dwellings on land at Goose Lane which is now complete (outline application reference 14/01449/OUT and reserved matters application reference 17/00863/REM). Land to the south is now identified as a reserve site for 30 dwellings in the made Quinton Neighbourhood Plan under Policy HO.2 (Reserve Site). The site has been assessed as being suitable and available for development, is supported by the local community. It could come forward relatively quickly to meet local housing need, including an element of affordable housing provision. It is not clear what status adopted Neighbourhood Plans will have upon adoption of the SWLP, including reserve sites within made Neighbourhood Plans (as per the example above). This position should be clarified through future policy drafting. 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? Response: A higher limit is appropriate It is difficult to specify a specific threshold / limit as the scale of development that is appropriate will depend on the location and also the growth strategy chosen. It is unclear at this stage as to the specific ‘threshold’ mechanism that may be applied. This approach could affect a range of settlements, in terms of service provision, population / size and location. Policy should allow for a range of sites to come forward, dependant on their characteristics and categorisation, thereby assisting in sustainable growth. The size limit will depend on the location and the site. Any development coming forward should seek to make efficient use of the site in accordance with paragraph 124 of the NPPF. For example, the College are promoting Land off Station Road/Campden Road, Long (SWLP REFID 273). This site is next to Meon Vale and is a sustainable location for a larger development. This is acknowledged by the site’s status as a reserve site in the emerging SAP (SAP site Reference LRS.A) with capacity for 90 dwellings. If this site did not feature in the chosen growth strategy, it could still form a logical location for development and it would be appropriate for a site of more than 10 dwellings to come forward. If there was a threshold of 10 or less, it could lead to piecemeal development that makes inefficient use of land which is contrary to paragraph 124 of the NPPF. Sites of less than 10 dwellings would also mean affordable homes would not be delivered in these locations. A similar case could be made for the College’s other land interest at Goose Lane, Lower Quinton (SWLP REFIS 272). This is a logical extension to the previously approved scheme at Goose Lane (outline application reference 14/01449/OUT and reserved matters application reference 17/00863/REM). 30 dwellings at this site would be an appropriate scale of development for a village of this size and has been supported in the made Neighbourhood Plan. The site is identified as a reserve housing site for 30 dwellings under Policy HO.2 S-S9: Please select the option which is most appropriate for South Warwickshire Agree with Option S9a to save all existing settlement boundaries where these are already defined. There should be allowance for a consistent approach to be adopted across the Stratford-on-Avon and Warwick Districts and for boundaries to be reviewed to allow for future growth. It should also be acknowledged that locations of recent growth, such as Meon Vale, do not have settlement boundaries identified. It would be relevant to review settlement boundaries for growth areas such as Meon Vale as they become self-sufficient settlements that could support further growth.

17. The settlement analysis does not consider all settlements in the Districts, it should also consider ‘networks of villages’ which can provide local amenities for new residential development. The settlement analysis should therefore be updated to include all settlements in the District, to do so would be in line with Paragraph 79 of the NPPG (2021) which states that: ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.’

30. All settlement boundaries should be reviewed as part of the SWLP, this will ensure consistencies of approach between Stratford-on-Avon and Warwick Districts, out of date boundaries can be reviewed which and there could be a subsequent increase in housing delivery.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire: DLPDS support the redevelopment of previously developed (brownfield) land and recognise that the majority of these sites will be located in urban areas. However, the Local Plan must also recognise that previously developed land exists outside of existing settlements and the future growth options, and can be developed sensitivelyand without adverse impacts having regard to the location and site context. A combination of the options set out in ‘Option S3.2a’ and ‘S3.2b’ is therefore required. The redevelopment of previously developed land, including the DLPDS land at Abbey Park, has a number of benefits. These include making good use of existing infrastructure; reducing the need to release greenfield land to meet the development needs of South Warwickshire; and reducing the amount of best and most versatile agricultural land that would be developed. NPPF Paragraph 119 is clear that planning policies should promote the effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies are required to set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously developed or brownfield land. In our view, a strategy that does not consider previously developed sites outside of urban areas does not meet the requirements of NPPF Paragraph 119. Local planning policies have previously recognised the special status of the DLPDS land at Abbey Park as previously developed land in the Green Belt. The previous Warwick District Local Plan 1996-2011 identified it as a ‘Major Developed Site in the Green Belt’, reflecting the national policy of the time. This facilitated a grant of outline planning permission to redevelop the site as a Business Park. Although the consented development of 7no. office buildings has been heavily marketed, only 3no. of the approved buildings have been constructed to date. An alternative mix of employment buildings was granted planning permission later, but low demand for office development at this location means that no buildings have been constructed since 2005. The current Warwick District Local Plan 2011-2029 (adopted in 2017), identifies the land at Abbey Park as a ‘Major Employment Commitment’. Although not fully developed, given the planning permissions and investment to date, the as yet undeveloped brownfield land at Abbey Park will not be returned to its original preBusiness Park function, as part of the Stoneleigh Deer Park. The consultation options presented focus on the requirement that the redevelopment of previously developed land have ‘a positive impact on the sustainability of the area’. However, this is out of step with the emphasis within Framework para. 119 which simply requires that the redevelopment of such land ‘safeguard and improve the environment’. The focus of the Local Plan should be adjusted so as not to prevent potential benefits of redeveloping brownfield land from being secured. The DLPDS land at Abbey Park would deliver such benefits, as part of a Registered Park and Garden (Grade II*), and facilitate tree planting and works to restore original features of the Park and Garden. This potential gain has been acknowledged in the officer reports for the Business Park permissions granted to date, which accepted that this part of the Park and Garden was substantially altered to construct the WWII Military Hospital. The redevelopment of previously developed land can be carried out in a way that protects existing assets and ensures safe and healthy living conditions, in accordancewith the Framework. For example, there are no listed buildings on the Abbey Park land, the nearest listed building being circa 100m from the southern boundary, beyond Stareton Lane (Grade II). A residential development can be carried out in a way that respects the setting of the listed building. Previous ground investigations have found the DLPDS land to be generally free of contamination. Although some remediation work is required for the promoted, the level of contamination is not an 'in principle' constraint to development. The development would secure its remediation. There are no statutory ecological designations directly affecting the site or within 1km. Some of the trees present are subject to Tree Preservation Orders and can be integrated into the redevelopment of the site. The land is mostly Flood Zone 1, which is the lowest possible risk of flooding. Although a small part of the site is affected by Flood Zone 3, this is outside of the area that would accommodate development, such that there are no constraints in flood risk terms. The existing employment uses at Abbey Park are already served by public transport, with a dedicated bus stop and shelter within the site. The stop is served by bus service 539, operatingMonday to Saturday between Coventry and Kenilworth, via Stoneleigh. When taking account of the information above, Abbey Park is an appropriate location and residential development would make best use of previously developed land.

Option S2-C: Intensification 11. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Rosconn Strategic Land 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. 12. 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-S3.2: Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Dependent on the results of the urban capacity study, it could be that brownfield development forms a part of our development strategy. Brownfield sites are frequently found within towns and can therefore often accommodate a higher development density. Prioritising development on brownfield land, especially at higher densities, might reduce the need for greenfield development. However, instead of developing all brownfield sites, this option looks to prioritise 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. In some instances, brownfield redevelopment can exacerbate issues and result in development occurring in unsustainable locations. This option aims to reduce such development. Option S3.2b: Prioritise development on brownfield land, incorporating existing buildings into development proposals wherever possible, irrespective of its location This option looks to prioritise the redevelopment of all brownfield land irrespective of whether the site is in a sustainable location. Whilst redevelopment of brownfield land is, on the whole, a sustainable approach, locating redevelopment in unsustainable locations can sometimes exacerbate issues within an area, and this is a risk of prioritising all brownfield sites for redevelopment. Option S3.2c: None of these 8. It is noted that the South Warwickshire Urban Capacity Study (October 2022) has concluded on capacity that: ‘This capacity of around 19,950 compares to a housing need for South Warwickshire over the new plan period of 30,750. This housing need figure is subject to change, and is also likely to require the addition of a buffer to allow choice and competition in the market in accordance with Planning Practice Guidance. We have sought to ensure that the assumptions underlying these figures strike an appropriate balance between conservatism and optimism to ensure robustness – whilst there may be some scope to further optimise capacities, particularly if the SWLP were to include policies to require the higher end of our established optimised density ranges, this is likely to require a higher burden of evidence in order to ultimately demonstrate that the SWLP is a sound local plan. A theoretical exercise to consider the potential yields from car park consolidation has indicated that between 800 and 3,400 dwellings could be created. This would however require significant levels of intervention and management to be realised. The shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire, where we have identified potential yields of up to 3,400 dwellings. However, this would necessitate a significant programme of intervention and management in order to be realised. It may also be possible to apply the optimised densities established through the Urban Capacity Study to some sites which have been allocated in existing local plans but which do not yet have planning permission (Site Category 2). However, whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.’ [emphasis added] 9. Therefore, the Council(s) evidence base clearly demonstrates the need for the release of greenfield sites. Q-S5.2: Do you think new settlements should be part of the overall strategy? Yes | No | Don’t Know 18. Spitfire do not object to the consideration of new settlements as part of the Council’s Growth Option. 19. A range of sites varying in scale and size should be explored in order to secure the delivery of new homes. The expansion of existing settlements and new settlements allocated in the Local Plan should also be explored further to see whether there is capacity to be extend these further. Smaller sites are likely to have no significant infrastructure or utility constraints. The site can be accessed off public highway, the site is in the control of a developer (Spitfire) which makes it a deliverable site. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? Yes | No | Don’t Know Spitfire have no objection to this growth option being explored but the end goal must be that development is located sustainably and can utilise and improve existing sustainable modes of transport. This option should be assessed against the other options being explored in order to confirm the overall infrastructure requirements of this development option. Q-S8.2: Please select the option which is most appropriate for South Warwickshire 27. A higher limit is appropriate for individual sites this will ensure flexibility and a subsequent increase in housing delivery and will ensure sites also deliver much needed affordable homes. Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Any revisions to existing boundaries, and consideration of which settlements have boundaries, would be saved for Part 2 plans and NDPs. The advantage of this approach is that waiting until Part 2 is likely to mean more detailed information is available – for example non-strategic allocations will likely not be made until Part 2, so waiting for these to come forward means any boundary revisions can accurately reflect new allocations. The disadvantages are that inconsistencies of approach between Stratford-on-Avon and Warwick Districts would not be addressed in the short term; and it results in a longer time period to address any out-of-date boundaries. 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. The aim would be to achieve a consistent approach across Stratford-on-Avon and Warwick Districts regarding the type or size of settlement that has a defined boundary. The main impact is on where limited infill development is permitted, and where ‘open countryside’ policies apply. The disadvantage is that some nonstrategic land allocations will likely not be made until Part 2 plans come forward. In such cases, it becomes difficult to make appropriate revisions to boundaries in advance of these non-strategic allocations. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire 28. All settlement boundaries should be reviewed as pry of the SWLP, this will ensure consistencies of approach between Stratford-on-Avon and Warwick Districts, out of date boundaries can be reviewed which and there could be a subsequent increase in housing delivery.

Please take notice that I object to the Wootton Wawen housing development plan. The proposal for 400 homes on green belt in a small village is outrageous! The “village “ feel would be gone forever ! The infrastructure is non existent apart from one village shop, two pubs, a train station and school and could NOT support 400 more homes increasing the population by at least 1600 ?! Green belt should be protected at all costs for the sake of a well balanced environment. The village of Wootton Wawen floods during high river tides …. The proposed housing development would add to this issue for many householders .. Preventing water draining away quickly , creating more traffic when roads blocked through flooding .. and more tensions on the village and disrupting present individual flood defence schemes which have been developed by individuals to protect their properties ! It is understood that since writing the plan there has been a shift in the Government’s position. M Gove stated that Green Belt does NOT have to be sacrificed by local plans and should be protected where possible. Consequently there is no longer pressure from the government as there was when the first plans were drawn up! Top down housing figures are often unrealistic … Wootton Wawen’s plan is un realistic and an abuse of the village way of life. Town and city populations benefit from escaping and enjoying the countryside ! It is important that the beautiful English villages are protected for all to enjoy !

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 take notice that I object to the Wootton Wawen housing development plan. The proposal for 400 homes on green belt in a small village is outrageous! The “village “ feel would be gone forever ! The infrastructure is non existent apart from one village shop, two pubs, a train station and school and could NOT support 400 more homes increasing the population by at least 1600 ?! Green belt should be protected at all costs for the sake of a well balanced environment. The village of Wootton Wawen floods during high river tides …. The proposed housing development would add to this issue for many householders .. Preventing water draining away quickly , creating more traffic when roads blocked through flooding .. and more tensions on the village and disrupting present individual flood defence schemes which have been developed by individuals to protect their properties ! It is understood that since writing the plan there has been a shift in the Government’s position. M Gove stated that Green Belt does NOT have to be sacrificed by local plans and should be protected where possible. Consequently there is no longer pressure from the government as there was when the first plans were drawn up! Top down housing figures are often unrealistic … Wootton Wawen’s plan is un realistic and an abuse of the village way of life. Town and city populations benefit from escaping and enjoying the countryside ! It is important that the beautiful English villages are protected for all to enjoy !

Option S2-C: Intensification 5. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Rosconn Strategic Land 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. 6. 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-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? 33. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Rosconn Strategic Land agree that a threshold approach would be appropriate for any settlement listed within Option 5 not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66. 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? 34. Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the size and availability of suitable land identified. The threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire The WMHAPC supports the option for brownfield development that maximises the delivery of affordable housing in the most sustainable locations. However, it is evident that a level of greenfield development will be required to meet the housing needs of South Warwickshire. Page 36 of the South Warwickshire Urban Capacity Study (2022) shows that there is likely to be a shortfall in the capacity of South Warwickshire to accommodate its housing need on brownfield land of some 10,800 dwellings for the plan period of 2025-2050: “However, whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.” The SW councils should be cautious to a brownfield led approach to development as it may hinder the delivery of affordable housing within the area. It is widely recognised that the development of brownfield land often has cost implications that negatively impact the viability of delivering affordable homes at such sites. In considering the evidence, a balanced combination of a greenfield and brownfield led development should be considered, as explained by the South Warwickshire Urban Capacity Study.

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? 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? In response to questions Q-S8 1 and 2 it is important that the SW councils recognise the importance of small sites in addressing local affordable housing needs by not only allowing for a level of small scale development that is proportionate to the existing settlement but also through the delivery of Rural Exception Sites. As such, the WMHAPC suggests that the SW councils offer a level of flexibility within policy to allow for the delivery of ‘Rural Exception Sites’ beyond the spatial growth strategy that the Council opt for. It is important to acknowledge the value of ‘rural exception sites’ in delivering affordable housing options that address local needs. Paragraph 78 of the NPPF (2021) explains that “local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs”. It is understood that the Policy H3 of Warwick Local Plan addresses Rural Exception Sites. This policy should be carried across into the South Warwickshire Local Plan to allow for the delivery of affordable housing outside of the SW councils’ spatial growth strategy. However, in its present form Policy H3 is severely restrictive in the evidence required to justify such a scheme, Policy H3 states: a) “The proposal will meet a particular local housing need, as identified in detailed and up to date evidence from a parish or village housing needs assessment, and it can be demonstrated that the need cannot be met in any other way” Following PPG (Paragraph: 012 Reference ID: 67-012-20210524), the WMHAPC suggests that the SW councils reconsider the wording of Policy H3 to allow for sufficient flexibility, whilst also ensuring the affordable housing needs of rural communities are able to be addressed. In line with PPG (Paragraph: 015 Reference ID: 67-015-20210524) the SW councils may wish to strengthen its working relationships with relevant groups to ensure the delivery of rural exception sites. The WMHAPC are well placed to make a meaningful contribution to such discussions.