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

I will limit my feedback to Bearley, over the past 10 years, countless man-hours, questionnaires, cost and public meetings, the Local/village plan was developed, approved and submitted all as part of the local and national requirements. Within this plan, housing and other needs were identified and I believe agreed with Stratford DC - this plan is then applicable until 2030. The plan established the current and longer term needs for Bearley in line with Stratford District Council's wider plan. Is this plan in force or has it simply, been ignored - if so, why? and on what basis? Feedback/Questions 1. The report states Bearley train station offers connections to Earlswood, Warwick amongst other locations, this is simply not the case - the station is hardly used due to its complete lack of meaningful services and connections. 2. The road through Bearley to Snitterfield is a B road, it is not designed or able to take the traffic that already uses it - especially the volumes of lorries (if you look at the damage to the road and verges it is clear that the road cannot take existing volumes) - by adding a potential large scale housing development with such poor road infrastructure, along with a limited bus service and no schools etc seems untenable. 3. The Bearley plan identified housing needs using infill and other sensible measures - if an increase is warranted, surely using the approach that takes into account the existing size, limited infrastructure and facilities is a sensible approach? 4. The SWLP does not outline what the proposed development would be made up of, number of houses or facilities, access to and from the two areas etc. 5. Bearley currently has c.300 houses with limited infrastructure and road system to match - nowhere in the SWLP takes this into account leading me to question how the red and blue zones have been calculated - would appear a pen was taken to a map without any background information known or used to make an informed proposal 6. Would request that more details are provided that clearly and simply outline 1. Methodology and sources for the proposed red and blue areas provided to allow full and open scrutiny 2. Timelines for open and transparent consultation on the SWLP allowing residents to fully understand the options and needs properly 3. What housing type options are available - e.g. infilling and purposeful house building v large scale developments to meet the same aims and objectives 4. How will the greenbelt and areas of outstanding natural beauty be protected and managed to ensure wildlife and peoples access to open spaces is not impacted. In summary, I would ask that more time is given to fully understand the needs of the SWLP, what the SWLP is aiming to achieve and how we can work with SDC and WCC to support the wider needs, alongside those who live in Bearley.

Option S2-C: Intensification 8. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Bloor Homes 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. 9. 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? 36. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Bloor Homes 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? 37. 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: 3.12. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.13. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.14. Growth at existing settlements across the Joint Plan area should form part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. 3.15. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.16. In order to develop the most sustainable pattern of development, growth at existing settlements should be in sustainable locations. It is important that appropriate levels of growth are apportioned to existing settlements in order to maintain the vitality and viability of settlements, support new and existing infrastructure requirements and provide an appropriate mix of housing for the area. 3.17. Studley is identified as one of 22 small settlements. It should be noted that the ‘small settlements’ are the only areas assessed at this stage aside from seven broad locations for developments (the largest seven settlements across the Districts) and potential new settlement locations. It should be noted that small settlements are sustainable locations for development. This site would allow for a sustainable development close to existing services and facilities. 3.18. As set out in the Sustainability Appraisal at Table 5.1, Studley scores similarly to the other small settlements assessed. It is noted that other small settlements score higher than Studley against Education and Accessibility. This is discussed in more detail in following sections however Studley has primary schools and a secondary school within the village. It should also be noted that the SA at this stage does not consider any mitigation. Growth at Studley would assist in supporting and likely enhancing the existing public transport provision which would mitigate any accessibility concerns. 3.19. It is clear that this site is located in an entirely sustainable location and should be positively considered as a location for growth. Issues S6: A Review of Green Belt boundaries 3.24. The Issues and Options consultation document does not set out any specific question on Green Belt matters, but these representations support a review of the Green Belt boundary as part of the Plan making process. 3.25. As set out in the NPPF para 136, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of Local Plans. Moreover, strategic policies should establish the need for changes to Green Belt, and where proposed, the amended boundaries should be able to endure in the long term, i.e. Green Belt boundaries will not need to be altered at the end of the plan period. 3.26. NPPF para 137 requires exceptional circumstances to include evidence of the examination of all other reasonable options for meeting an identified need for development. Importantly, in reviewing Green Belt boundaries sustainable patterns of development should be taken into account. 3.27. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and review growth options, where the most sustainable form of development is likely to be around existing settlements, it is therefore imperative that the Local Plan evidence base includes a Green Belt review. The Councils’ recognition of this in relation to a number of the proposed growth options is supported. 3.28. If a Green Belt boundary review is not undertaken, development will need to ‘jump the Green Belt’ which would result in an isolated pattern of development. Studley is a settlement which is surrounded by Green Belt with limited options for growth without Green Belt release. Studley is a sustainable location for further growth and, as set out in this representation, the site represents a sustainable location for residential development and should be released from the Green Belt through the review associated with this Plan. Q-S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 3.29. It is noted that the Issues & Options document has reduced the previous seven growth options presented in the Scoping Consultation to five options as outlined above through refining and combining options, including Option 2 sustainable travel (combination of rail and bus corridor) and Option 3 economy (combination of socio-economic and enterprise hub options). In this consultation document, Option 4 sustainable travel and economy effectively combines Options 2 and 3. It is clear from this process that the growth option to be pursued will represent a combination of all five options outlined above. 3.30. The options now presented in the Issues and Options, apart from Option 5: Dispersed, perform broadly similarly to each other in the SA (Table 7.1) suggesting not one option may have significantly more or less impact than any of the others when considered against the SA Framework. At this stage, the SA has not considered any mitigation or site-specific options for growth within settlements identified within the ‘dispersed’ option (5). There could be significant variance in how each settlement and individual sites would perform against the SA objectives. All of the growth options could deliver sustainable development and a combination of all options will be the most appropriate option for the development of the Plan going forward. 3.31. By necessity, the strategy will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66 year supply of housing. Land from other sources will therefore be required and it is important that all options are considered in taking the Plan forward. 3.32. Combining sustainable travel (including rail) and economy will naturally direct most growth to the larger, more sustainable settlements. However, it is important that appropriate, proportionate growth is directed to smaller settlements in order to support the continued viability and vitality of these settlements going forward. This would include supporting or enhancing sustainable travel options at these locations. This needs to be positively planned for as part of the South Warwickshire Local Plan and as such an element of dispersal should form part of the final growth option. This will require a careful consideration of all of the options, including growth at existing main settlements, growth at smaller existing settlements, proximity to services and jobs, availability of infrastructure or opportunities for infrastructure delivery and a Green Belt boundary review to ensure development is not isolated beyond the defined Green Belt boundaries. 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? 3.33. The supporting text for this question confirms that the aim of this approach would be to allow for development within or adjacent to existing settlements. This provides greater scope of these settlements to accommodate growth than the current infill only approach. The proposed approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. 3.34. An across the board threshold limit of 10 dwellings is not supported. The amount of development different settlements can accommodate will vary significantly depending on various factors, such as existing services and facilities, local need for housing and the suitability of the proposed site to accommodate a certain level of development. 3.35. In addition, developments of 10 or fewer dwellings are exempt from affordable housing. Even where a lower threshold is set, developments of this scale generally result in a commuted sum towards affordable housing elsewhere. This is due to a variety of factors, including that registered providers often will not take on a small number of dwellings in one location. It is clearly preferable to have affordable housing delivered on site wherever possible to meet local needs. Setting a more flexible threshold that would allow for a higher level of development where appropriate would support greater on-site affordable housing provision. Q-S9: Please select the option which is most appropriate for South Warwickshire 3.36. The South Warwickshire Local Plan provides the opportunity to review all settlement boundaries and ensure they will be fit for purpose across the plan period. Saving all existing settlement boundaries is unlikely to be effective in positively planning for plan-led growth across the plan period. This should apply all settlements as part of the exercise will be to assess which settlements which would benefit from a defined boundary. 3.37. To be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. 3.38. In addition, settlement boundaries will need to be reviewed and amended to take account of new allocations. 3.39. For example, the development boundary for Studley should be reviewed to allow for the removal of this site from the Green Belt and inclusion within the development boundary to deliver sustainable residential growth.

9. Land South-West of Studley 9.1. Persimmon is promoting land south-west of Studley for residential development and on-site green infrastructure. It should be noted that this site would support development of sufficient scale to deliver highways infrastructure improvements in Studley which along with providing mitigation for any proposed development would also seek to provide a betterment to existing residents through relief of existing congestion. Options to deliver highway improvements will be explored in conjunction with the County Council as the Local Highway Authority. 9.2. The site comprises of agricultural fields with field boundaries defined by hedgerow and sporadic trees. The site is bordered by Bromsgrove Road, Node Hill, Jill Lane and The Slough road to the north (A448), beyond which is existing residential development associated with Studley. 9.3. The site is located at the settlement edge of Studley which is characterised by residential development of mixed character and age. The development of this site would form part of this context and would complement the existing residential use. Any development would be accompanied by a robust landscape strategy which would reflect the existing landscape character of the area. 9.4. The accompanying Vision Document sets out that the south-west of Studley is the least constrained option for growth for the village. A well-designed scheme would deliver residential growth and could accommodate complementary services and facilities for the village. Any scheme would be accompanied by a robust landscape strategy and would include a landscape buffer to the south to preserve the character of Studley and Middletown. As set out above, it is anticipated that the proposal would accommodate sufficient development to support the delivery of highway infrastructure improvements for the village which would deliver benefits for future and existing residents. Sustainability Appraisal SA 9.5. The majority of land south-west of Studley is included within the brown outline as ‘small settlement at Studley’ on Figure C.18.1. The site is shown to adjoin the built-up boundary. It is suggested that the outline should be expanded to include all land south-west of Studley up to the A435. 9.6. The assessment of Studley against the SA objectives is presented at Section C18.1 of Appendix C. It is acknowledged that, at this stage, the assessment covers a wide area and the ratings will not be applicable to each site within the settlement. Each SA Objective is considered with specific reference to the site below: 9.7. SA Objective 1 Climate Change: The land would deliver residential dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The land could also deliver additional local facilities and highway infrastructure improvements. 9.8. SA Objective 2 Flood Risk: The land is entirely within Flood Zone 1, land at lowest risk of flooding. There are limited areas of surface water flood risk within this area however this could be addressed by suitable design and sustainable drainage systems. It should be noted that land to the south-east of Studley is constrained by areas of Flood Zone 3 associated with the River Arrow. 9.9. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: The site is not designated as a Special Conservation Area (SAC), Site of Special Scientific Interest (SSSI), National Nature Reserve (NNR), ancient woodland, Local Nature Reserve, Local Wildlife Site, Local Green Space (LGS) or priority habitat. The SA refers to Rough Hill & Wirehill Woods SSSI as an important local designated site. This SSSI lies north-west of Studley and is separated from the site by existing built development. Any impact on the SSSI could be appropriately managed, including through sensitive design. Wirehill Woods is also an ancient woodland and is beyond the Natural England buffer distance. As noted above, there is also intervening built development. There are small areas of priority habitat (deciduous woodland) within the site that would inform a future masterplanning process. 9.10. SA Objective 4 Landscape: The land is characterised by residential development to the north. The accompanying vision document sets out that any design would be landscape-led and would look to reflect the pattern and scale of the landscape, integrate into its landscape context and create a high-quality environment for the settlement edge of Studley. 9.11. SA Objective 5 Cultural Heritage: The land is located close to two Grade II Listed Buildings. This would inform the design process for this site. It should be noted that land to the southeast of Studley is constrained by the presence of three Grade II* Listed Buildings and a Scheduled Monument. The setting of these assets would need to be carefully considered and would suggest growth should be directed towards other parts of the settlement. 9.12. SA Objective 6 Pollution: It is noted that there is small Air Quality Management Area (AQMA) within Studley (to the west of the High Street). This is located in the northern part of the village and the land south-west of Studley is the most separated from the AQMA of any of the potential growth directions. Impact on the AQMA could be managed and highway infrastructure improvements that could be supported by this proposal would likely lead to air quality improvements. The SA also identifies the River Arrow as a potential pollution receptor which would need to be managed. Coin Brook is also identified as a small tributary which runs south-west of Studley but is closest to Middletown and could be managed through appropriate sustainable drainage and landscaping. 9.13. SA Objective 7 Natural Resources: It is acknowledged that development of this land would result in a loss of agricultural land however this would be a minor loss in the context of the wider agricultural land in this area. The land is within a Mineral Safeguarding Area (MSA) however the site is relatively small compared to the MSA and given the location of adjacent residential development mineral extraction is unlikely to be acceptable in terms of residential amenity. 9.14. SA Objective 8 Waste: A residential development would generate a level of household waste however this can be managed with provision of suitable recycling facilities for all households. 9.15. SA Objective 9 Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing. 9.16. SA Objective 10 Health: Studley benefits from a good access to healthcare facilities with a GP surgery located in the village and the close proximity of the Alexandra Hospital (which includes an A&E department) in Redditch, immediately to the north of the settlement. There is also good access to leisure and recreation facilities within Studley with scope to provide on-site open space. 9.17. SA Objective 11 Accessibility and 12 Education: Studley benefits from a bus service providing frequent local services to Redditch and Stratford-upon-Avon. These locations have train stations for onwards journeys, including to Birmingham. There are also various local services and facilities within the local area, including a primary schools and a secondary school. 9.18. SA Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with Studley which include the employment areas to the north-west of the settlement. The village is also located close to the Alexandra Hospital and associated employment opportunities in Redditch which can be accessed via public transport. Summary 9.19. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.20. The Vision Document indicates how the land could be developed for residential use having regard to the constraints and opportunities. 9.21. The site benefits from a sustainable location within Studley and is well placed to meet the housing needs of the area. The site is well-placed to ensure easy access to a range of services and facilities including public transport. 9.22. The Vision Document illustrates that the south-west is the least constrained of the three growth options for Studley, the other two being north and south-east. The north is significantly constrained by existing leisure, recreation and ecological uses and the narrow gap between Studley and the neighbouring town of Redditch. To the south-east are areas of flood risk associated with the River Arrow and various designated heritage assets, notably Grade II* Listed Buildings and a scheduled monument associated with Studley Castle. The land to the south-west is comparatively free of constraints and provides a clear opportunity to support the growth of the village. This development could deliver benefits for the village, for example through highway infrastructure improvements. 9.23. The Vision Document also considers the purposes of the Green Belt and sets out that release of land in this area would not compromise these purposes. It also considers that the constraints associated with the other potential growth directions means that release these areas would compromise these purposes. 9.24. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.25. Persimmon has a land interest and is promoting the area for residential development. 9.26. Persimmon is an experienced national housebuilder with a proven track record of delivery across the country, including in South Warwickshire. 9.27. Persimmon’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation to the South Warwickshire Local Plan. 9.28. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.29. Persimmon has a land interest and are actively promoting the area for residential development. The site is available and could deliver housing in the first half of the Plan period. 10. Conclusion 10.1. This representation has been prepared by Pegasus Group on behalf of Persimmon Homes. 10.2. Persimmon are promoting Land South-West of Studley for residential development. The land is sustainably located adjacent to the built development edge of Studley and adjoins existing residential development. This land is suitable, available and deliverable and should be released from the Green Belt and identified as a location for future residential development as part of the South Warwickshire Local Plan. 10.3. These representations demonstrate that there are no significant constraints that would preclude the delivery of residential development in this area. 10.4. Persimmon welcome the opportunity to comment at this early stage of the plan preparation. If the Council require any further information in respect of the site to assist in the accurate assessment of this site, this can be provided upon request.

One noticeable omission from the plan is the idea of creating one new town for the whole area instead of infilling around existing conurbations. By requesting suggested sites the new town option is effectively discounted before the starting pistol has even been fired. It is surely the duty of any local authority to look at ALL options and to make unpalatable decisions based on need rather than decisions based on political expediency. The approach of a new town build would allow the next 50+ years of expansion to be planned for the whole South Warwickshire area and do much to protect existing conurbations. In addition it would ensure the proper provision of transport, health, commerce, jobs, leisure. It would also ensure ·The recent promotion of the 15minute city is achieved. Only the 20minute city receives cursory mention in the report -B5 B5.1. ·There appears to be no mention of the type of housing proposed. Correctly designed and implemented there are no real issues with multi storey constructions which would allow efficient use of footprint and potentially reduce footprint or allow provision of green space with developments.. ·Again there is no mention of aspiration in housing type. At the very least one would expect consultants to be aware of the award winning Goldsmith Street in Norwich designed by Mikhail Riches & Cathy Hawley for Norwich City Council. ·Looking at all the recent estates built in Warwickshire confirms a collection of bland boxes. Goldsmith Street confirms things can be very different. ·Kenilworth North:- ·4.5.22 Pollution of Source Protection Zone (SPZ). This would be a very serious event leading to (i) Possible potable water shortage (ii) Prosecution of Local Authority and Developer. As such it should not be so easily dismissed in the appraisal. ·4.5.31 Health Care. An increase in local population would surely require provision of additional facilities? Not as the plan suggests using existing facilities which are already stretched. ·4.5.36 Public Transport. The plan suggest using exiting routes but one would expect new routes to serve new developments. Sadly experience of the use of new bus routes is poor – witness the bus service provided from / to Kenilworth Station which failed to survive. Although mention is made of increased pollution due to vehicular transport this does not seem to take into account increasing density of electric / hydrogen power vehicles. Nor is any consideration given as to where those vehicles might rest whilst not in use. Given that such provision is sensible and should be allowed for it is critical development incorporates it from the start. People will not easily transfer from the convenience of the car to public transport. A noticeable increase in public transport frequency would be required, every 15minutes for rail and every 10minutes for buses. ·B5 B5.1 The area shown goes over the HS2 route and removes currently active farmland from use. How does the removal of farmland balance with the UK becoming self-sufficient in food production? Mentions 20minute neighbourhoods but not the more desirable 15minute? ·B5.2 A lot of drainage in Kenilworth North is via open surface ditches. No mention is made of this aspect when considering potential flooding when a large increase in potential runoff could cause these ditches to become overloaded leading to localised flooding. In the mitigation no mention of using porous surfaces to mitigate ground water runoff and thereby reduce, ideally eliminate flood risk. ·B5.6 Pollution – Watercourses. Again no mention of drainage ditches. Negative impact on SPZ, unacceptable one thinks. ·B5.10 No reference to University Hospital Coventry which at many times of the day would be easier to access compared to Warwick. GP Surgery no suggestion of increasing provision rather overload existing. ·B5.11 Not really in range of railway station without use of car – station is served by zero bus routes since the failure of the S route to attract custom. ·Kenilworth North West ·This proposal would totally ruin Kenilworth Castle and would doubtless receive vociferous opposition from numerous sources. The land behind the castle is of a rising nature so it is hard to see what if any mitigation measures could be implemented to preserve the visual aspect of the Castle in its setting. The next 25-50years provided an opportunity to provide habitations fit for the next 200 years, sadly one can have little hope this will be achieved as developers will, having got planning permissions seek to diminish the agreed plan. We shall see what develops in the next stage of the SWIP.

Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

ISSUE S1: GREEN AND BLUE CORRIDOR 2.10 The preliminary landscape proposal for the Land at Old Town, Gaydon Site has demonstrated that a range of elements such as: the retention of existing and new hedgerows, additional tree and woodland planting, and the potential ecological benefits associated with Sustainable Urban Drainage systems, will provide multiple ecological benefits. 2.11 Green and blue infrastructure can be incorporated within a development in a number of ways. As the layout design of such sites as Land at Old Town, Gaydon progress, 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 proposal. 2.12 Ellis Machinery would support Option S1a as preferable, considering the production of a Local Nature Recovery Strategy will come after the SWLP Spatial Growth Strategy has been determined. ISSUE S4: GROWTH OF EXISTING SETTLEMENTS 2.13 Yes, Ellis Machinery consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. 2.14 As stated within the consultation document, South Warwickshire has a dispersed settlement pattern (as set out in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy) and is home to a significant number of existing settlements of varying sizes. The approach to growth across South Warwickshire seeks to maximise the capacity of its existing urban areas in order to meet development needs to 2050. The approach acknowledges growth around the edges of the existing settlements, potentially alongside and in combination with other options such as new settlements. 2.15 Gaydon is identified as a Category 4 Local Service Village (LSV) in the Stratford-on-Avon Core Strategy (SOVCS). Policy CS.15 of the Local Plan sets out the distribution of development across the District, promoting a pattern of balanced dispersal in settlements. These smaller villages often have the capacity (in terms of limited impact on landscape, biodiversity etc) to accommodate small/medium scale residential developments. 2.16 The Old Town, Gaydon Site immediately adjoins the built-up area boundary of Gaydon with existing residential development to the north and east. The Site would be well connected to the built-up area of the village and would: • Assist in meeting the District’s housing need, including a diversity of housing stock for both market and affordable housing; • Assist in maintaining the viability and vitality of the Gaydon village services and facilities, and • Ensure that there is a supply of small and medium sized sites, that are free of infrastructure constraints and can be delivered quickly. 2.17 Given the pressing need for additional housing within the Stratford-on-Avon District, Gaydon is a sustainable location to accommodate additional housing growth. Initial Technical Reports for the Site have been prepared and included in the Call for Sites submission. The Technical Reports demonstrate that the Site has no constraints that would preclude a speedy delivery of new homes. 2.18 Accordingly, it is considered that the Site should be allocated as a residential site within the South Warwickshire Local Plan. ISSUE 5: THE POTENTIAL FOR NEW SETTLEMENT 2.24 Ellis Machinery does not object to the consideration of new settlements as part of the Council’s Growth Option. 2.25 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 that are unlikely to have significant infrastructure or utility constraints, such as Land at Old Town, Gaydon, as well as providing direct benefit to the local community are able to be delivered quickly. ISSUE 8 SMALL SCALE DEVELOPMENT OUTSIDE THE SPATIAL GROWTH OPTION 2.30 No, the scale of a development should reflect the character of the locality and any specific housing need of the local area. ISSUE S9: SETTLEMENT BOUNDARIES AND INFILL DEVELOPMENT 2.31 Ellis Machinery would support Option S9a, existing boundary that have already defined within the Core Strategy, Local Plan, emerging SAP or an NDP.

I am concerned that the Local Plan does not sufficiently protect current green belt areas and that proposals appear to go beyond Brownfield sites for development The way in which the proposals are drafted are difficult to navigate but I would like to express my views as a North Leamington resident who enjoys all the green spaces in and around the town and as an allotment holder. I do not want to see development in green spaces or to see any reduction in green spaces to facilitate development. It has been deeply disappointing to see all the unnecessary destruction of the green belt areas where HS2 is under construction and I am very concerned that the Plan may infringe on the green belt still further. It is the green environment that Leamington is known for and it benefits its residents and visitors in many ways. I do not want to live in a built up area devoid of nature and green spaces. In addition, the green space provides the town and its neighbouring villages with their boundaries and distinct identities. I do fear that the local and national governments have lost sight of what genuinely matters to residents and citizens. Our green spaces and rivers are at risk - there is a lack of creative and innovative thinking about climate change - electric cars aren't yet accommodated (surely all town centre car parks should have a charge point in every other space?) our town centre has little to offer other than food and drink because rates and parking charges are too high and our streets are not safe for women. In short, I object to any proposals that impinge on, reduce or eliminate current green belt land.

Please take the following comments into account as part of the above consultation specifically relating to Chapter 4, Issue S6 concerning growth opportunities in the green Belt: 1. Local ratepayers greatly value the Green Belt land around North Leamington. It is a vital open space area used daily by hundreds for physical exercise. 2. It is good quality agricultural land providing breathing space between Kenilworth and Leamington and must make an important contribution to the air quality, which we all know is a problem in parts of Leamington and Warwick. 3. An analysis of the 54% of respondents favouring growth opportunities in the Green Belt is highly suspect and if subjected to analysis, would surely show such respondents as having a vested interest in developing it. 4. Similar proposals to encroach upon the Green Belt in 2017 were rejected by the Planning Officer and his reasons for the rejection are just as valid today as they were 6 years ago. 5. We all have benefitted from the foresight of a previous generation in establishing Green Belts nationwide and it would be a betrayal of our responsibility to future generations, if we were to disrespect that responsibility. 6. First and foremost the council should be giving priority to brownfield development. 7. Finally, any review of growth opportunities within the Green Belt flies in the face of current Government policy.

I'm writing in especially to object The Green Belt being built on. Please don't do this. I run a pet care business and regularly do my group dog walks here. It's my safe space and my routine I have with the dogs. They absolutely love walking here, it's spacious, peaceful and has little distractions. It's the only appropriate place to walk and is situated near where all of my clients live. My clients are all very upset about the plans being made also, particularly those who live close to or whose houses back onto the area. I would really struggle to do the group walks anywhere else; even Newbold Comyn. So that's my livelihood out the way. Secondly, this is such a beautiful stretch of land so many people enjoy walking on and has lots of wildlife. I've observed Deers, Birds, Squirrels, Foxes, Butterflies in abundance, please don't destroy their home. I'm absolutely devastated to hear about the plan to do this to this area. Please don't do it :( Whoever is in charge of this decision, please take your time to have a peaceful walk there one evening, especially at sunset in Spring or Summer. You will really see how beautiful it is and what an absolute shame it would be to do this. I know there's a need for more houses but please don't ruin this area.

Can I please register an objection to 11.56 and 2.21 [Call for Sites REFID 195 and REFID 193]. Both in the parish of Ashow. The 10 residences. The private sewage provision is at capacity. These home would need their own septic tanks or a new sewage plant. The access road between [addresses in Ashow] cannot be used for access under any circumstances. We require full and unfettered use of our garage to the rear 24 7. It is not wide enough for more than one car. The light industrial use would invade green belt land and that stretch of road is already dangerous - cars cannot be seen and any turning off into this land would be dangerous. There has already been significant natural habitat destruction with the nearby HS2. Any further destruction would be unacceptable.

• QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. • Q-S5.2 - New Settlements: It is wholly unacceptable to consider the development of a new settlement within greenbelt land where there are no “exceptional circumstances” to do so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are being considered in the current consultation document. A new settlement should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. • Q-S7.2 – For the remaining spatial growth options, I feel it is imperative that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF “exceptional circumstances” principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. As I indicated above, the climate emergency should not be used as a justification to develop greenbelt land. • Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. The plan should allow for more small-scale growth developments to come forward in greenbelt areas. • Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. Permitted development rights were removed from many properties in Weston based on the proximity of the properties to the Greenbelt. Planning permissions requests are equally draconian for the same reasons. To propose such a development is totally contradictory to this principle. The area around Weston does not have the infrastructure to support such a massive development. Enabling the necessary infrastructure would result in further destruction of irreplaceable greenbelt. HS2 is causing enough damage to the greenbelt area in Warwickshire as it is. Destroying further multiple hectares of greenbelt unnecessarily is preposterous when there are multiple alternative brownfield options which could be considered. The Climate Emergency must not be used as justification to develop on greenbelt land. The carbon release associated with ripping up greenbelt areas is immense. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). It is not 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 wish to comment on the need to secure/defend the green belt North of Leamington Spa for future generations. 1. It maintains the distinct identities of Leamington Spa and Kenilworth, and assists in maintaining Leamington Spa's setting and special character (vital in attracting people to the area to promote tourism and retail facilities necessary for income and employment) 2. This area is much loved by residents of Leamington Spa and visitors, and is much used for recreation and enjoyment of nature 3. The agricultural land is of high quality, important for the sake of national food security. 4. It is frequently referred to as "The lungs of Leamington" Its development would not be in line with Government policy and would be a tragic waste, resounding down the generations of locals and visitors alike. We seem to be constantly needing to repeat defence of this for the future. Why? Our area has suffered greatly due to HS2. Further decimation/destruction/blighting would be devastating.

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. If you have any further comments, please write them here.: Please think very carefully before allowing this wanton devastation of Kenilworth to occur.. Please think now of future generations. I’m sure you lot enjoyed the open countryside at some point!

1. The Green Belt north of Leamington is important for many reasons: • It is high quality agricultural land which should be safeguarded for the sake of national food security. • Its footpaths offer recreational and health benefits for many people in the town of Leamington Spa who can access the area on foot. The number of people using the footpaths increased hugely during periods of lockdown and this has continued since. • It prevents a sprawling northwards of the town of Leamington Spa and forms a green ‘northern gateway’ to the town. This in turn helps Leamington to maintain its setting and special character. • It helps to maintain the distinct identities of the towns of Kenilworth and Leamington Spa and prevents them merging into one another. • It assists in urban regeneration, by encouraging the recycling of derelict and other urban land, in line with the Government’s “Brownfield First” pledge. 2. It is not necessary or appropriate to develop the Green Belt north of Leamington because: • It is not in line with current Government policy. • The statistic used in the consultation in support of Green Belt development is misleading. This says that 54% of respondents support the exploration of Green Belt growth opportunities, without mentioning that 45% of respondents were developers, landowners and businesses. • The Green Belt north of Leamington fulfils all five of the stated purposes of the Green Belt. • The Green Belt north of Leamington is high quality agricultural land which should be safeguarded to promote food security. • The planning team explored options which placed development outside of the Green Belt yet it has presented none of these in the consultation document.

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are no exceptional circumstances to justify doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, there are ample non-greenbelt options for this. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas and stations in greenbelt locations. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion due to people travelling from the North to the South of the town. A new station in the greenbelt is unacceptable. The climate emergency must not be used as justification to develop on greenbelt land - this is a weak argument as there are other ways of mitigating the climate emergency without developing on greenbelt. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small-scale development is appropriate in greenbelt areas. I do not feel the plan should allow for more small-scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages, due to the impact this would have on the rural character of the North Leamington Greenbelt area. Additionally, the infrastructure in and around these small villages is not sufficient to support further development. 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 and can in no way be considered representative of the area’s population. 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 small number of respondents should not be used as a basis for decision-making, particularly with regard to an issue as important as development or review of the greenbelt.

On 7th February 2023, a Commons Research Paper on The Green Belt reminds us that three of the purposes of such areas are: • to check the unrestricted sprawl of large built-up areas, • to prevent neighbouring towns merging into one another, • to assist in safeguarding the countryside from encroachment Furthermore it emphasises that: ‘On protecting the Green Belt, the NPPF urges Local Planning Authorities (LPAs) to maximise the use of suitable brownfield sites before considering changes to Green Belt boundaries. The NPPF demands that there should be “exceptional circumstances” before Green Belt boundaries can be changed and says that inappropriate development is harmful to the Green Belt and should be approved only in “very special circumstances”.’ We know that Warwick and Leamington have already ‘merged into one another’. Surely it is essential that the Local Authority strive to ensure that this does not happen with the next neighbouring town? When looking at the local plan, it is shocking to see the percentage of Green Belt land that lies north of Warwick/Leamington and south of Kenilworth that is being considered for re-designation for building. It would appear to be about a fifth of that green belt land when you realise that over 283 hectares are identified in just the REFID areas numbered 140, 177, 2, 116, 231, 211, 174, 210, 531, 93 and 567. REFID 531 This area, with the Landname ‘North of Leamington Spa’ is not only part of the Green Belt but is a green lung for those living in the north of the built-up areas of Leamington and Warwick - and yet it is the largest of the areas identified for potential building. The west/east footpath from Bamburgh Grove to Old Milverton Road (and the north/south path that links from Guys Cliffe Ave) is used daily by people and their dogs - and clear irrefutable evidence of this is seen in the clear image of the footpaths on this Google Satellite photo - lines created simply by footfall! Importantly, this path is used by hundreds of people regularly who reach this green path BY FOOT from their own dwellings across the breadth of the suburban areas in the north of Leamington. Access to this great green space is not only treasured by people but significantly benefits their physical health and mental well-being - without involving any cost to the Local Authority because it is simply a footpath. In fact, its benefits are increased because the path links to those further west, thereby creating circular walks that are regularly used by walkers from the north of Warwick as well. Other concerns about building housing in this zone includes the fact that all three Primary Schools that lie close to this area are all over subscribed already. Furthermore, REDIF 531 creates a northern border to a residential area bordered on the west by Old Milverton Road and on the south by Rugby Road - both routes that already have significant issues with traffic flow. REDIF 231 It is very well known by local residents that the Hill Wootton Road junctions on both the West and the East are very dangerous - a crossroad with the B4115 under a railway bridge and up a steep slope on to the busy A452 Kenilworth Road. Furthermore, flooding of the road is not unusual. It seems somewhat foolhardy to propose increasing traffic by building more housing which would have to use this road for access.

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. If you have any further comments, please write them here.: I have very little faith in the WDC ability to consult and take on board the wishes of the community

Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 3.12. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.13. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.14. Growth at existing settlements across the Joint Plan area should form part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. 3.15. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.16. In order to develop the most sustainable pattern of development, growth at existing settlements should be in sustainable locations. It is important that appropriate levels of growth are apportioned to existing settlements in order to maintain the vitality and viability of settlements, support new and existing infrastructure requirements and provide an appropriate mix of housing for the area. 3.17. Wellesbourne is identified as one of 22 small settlements. It should be noted that the ‘small settlements’ are the only areas assessed at this stage aside from seven broad locations for developments (the largest seven settlements across the Districts) and potential new settlement locations. It should be noted that small settlements are sustainable locations for development. The Site would allow for a sustainable development close to existing services and facilities. 3.18. As set out in the Sustainability Appraisal at Table 5.1, Wellesbourne scores similarly to the other small settlements assessed. It is noted that other small settlements score higher than Wellesbourne against Education and Accessibility. This is discussed in more detail in following sections however Wellesbourne has a primary school and has the Wellesbourne Campus of the University of Warwick located north of the main village. It should also be noted that the SA at this stage does not consider any mitigation. Growth at Wellesbourne would assist in supporting and likely enhancing the existing public transport provision which would mitigate any accessibility concerns. 3.19. It is clear that this Site is located in an entirely sustainable location and should be positively considered as a location for growth. Issues S6: A Review of Green Belt boundaries 3.24. The Issues and Options consultation document does not set out any specific question on Green Belt matters, but these representations support a review of the Green Belt boundary as part of the Plan making process. 3.25. As set out in the NPPF para 136, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of Local Plans. Moreover, strategic policies should establish the need for changes to Green Belt, and where proposed, the amended boundaries should be able to endure in the long term, i.e. Green Belt boundaries will not need to be altered at the end of the plan period. 3.26. NPPF para 137 requires exceptional circumstances to include evidence of the examination of all other reasonable options for meeting an identified need for development. Importantly, in reviewing Green Belt boundaries sustainable patterns of development should be taken into account. 3.27. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and review growth options, where the most sustainable form of development is likely to be around existing settlements, it is therefore imperative that the Local Plan evidence base includes a Green Belt review. The Councils’ recognition of this in relation to a number of the proposed growth options is supported. Q-S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 3.29. It is noted that the Issues & Options document has reduced the previous seven growth options presented in the Scoping Consultation to five options as outlined above through refining and combining options, including Option 2 sustainable travel (combination of rail and bus corridor) and Option 3 economy (combination of socio-economic and enterprise hub options). In this consultation document, Option 4 sustainable travel and economy effectively combines Options 2 and 3. It is clear from this process that the growth option to be pursued will represent a combination of all five options outlined above. 3.30. The options now presented in the Issues and Options, apart from Option 5: Dispersed, perform broadly similarly to each other in the SA (Table 7.1) suggesting not one option may have significantly more or less impact than any of the others when considered against the SA Framework. At this stage, the SA has not considered any mitigation or site-specific options for growth within settlements identified within the ‘dispersed’ option (5). There could be significant variance in how each settlement and individual sites would perform against the SA objectives. All of the growth options could deliver sustainable development and a combination of all options will be the most appropriate option for the development of the Plan going forward. 3.31. By necessity, the strategy will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66 year supply of housing. Land from other sources will therefore be required and it is important that all options are considered in taking the Plan forward. 3.32. Combining sustainable travel (including rail) and economy will naturally direct most growth to the larger, more sustainable settlements. However, it is important that appropriate, proportionate growth is directed to smaller settlements in order to support the continued viability and vitality of these settlements going forward. This would include supporting or enhancing sustainable travel options at these locations. This needs to be positively planned for as part of the South Warwickshire Local Plan and as such an element of dispersal should form part of the final growth option. This will require a careful consideration of all of the options, including growth at existing main settlements, growth at smaller existing settlements, proximity to services and jobs, availability of infrastructure or opportunities for infrastructure delivery and a Green Belt boundary review to ensure development is not isolated beyond the defined Green Belt boundaries. 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? 3.33. The supporting text for this question confirms that the aim of this approach would be to allow for development within or adjacent to existing settlements. This provides greater scope of these settlements to accommodate growth than the current infill only approach. The proposed approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. 3.34. An across the board threshold limit of 10 dwellings is not supported. The amount of development different settlements can accommodate will vary significantly depending on various factors, such as existing services and facilities, local need for housing and the suitability of the proposed site to accommodate a certain level of development. 3.35. In addition, developments of 10 or fewer dwellings are exempt from affordable housing. Even where a lower threshold is set, developments of this scale generally result in a commuted sum towards affordable housing elsewhere. This is due to a variety of factors, including that registered providers often will not take on a small number of dwellings in one location. It is clearly preferable to have affordable housing delivered on site wherever possible to meet local needs. Setting a more flexible threshold that would allow for a higher level of development where appropriate would support greater on-site affordable housing provision. Q-S9: Please select the option which is most appropriate for South Warwickshire 3.36. The South Warwickshire Local Plan provides the opportunity to review all settlement boundaries and ensure they will be fit for purpose across the plan period. Saving all existing settlement boundaries is unlikely to be effective in positively planning for plan-led growth across the plan period. This should apply all settlements as part of the exercise will be to assess which settlements which would benefit from a defined boundary. 3.37. To be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. 3.38. In addition, settlement boundaries will need to be reviewed and amended to take account of new allocations. 3.39. For example, the development boundary for Wellesbourne should be reviewed which would allow for the inclusion of this Site within the development boundary to deliver sustainable residential growth.

I am particularly concerned about plans to build on green belt land. My understanding was that green belt land was designated as such to protect such land in many ways. I was also under the impression that the current government have indicated that greenbelt land should not be built upon. Here are my concerns in detail: 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. In surveys residents say 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 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 and undergo diversification of farming techniques. 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. 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 merging of the boundaries of Kenilworth and Leamington. 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 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” (p. 18, para 91). 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” (p.34, para 201). 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 … … urban regeneration in favour of greenfield development.

I object to any further destruction of the fields/green belt around Leamington and surrounding areas. In my time living here, we have seen huge amounts of building (mostly residential) and the impact on traffic is significant. Fields and open spaces are vital for good health and wellbeing. I strongly object to further growth plans. And I wish the process to complete the online objections was easier too!

I am writing with comments on the above proposed green-belt building development. This site connects two pleasant, rural and historic villages. The area contains attractive countryside with pleasant walks along the River Leam and Millennium Way. Obviously green-belt development should be permitted rarely, and only in special and necessary circumstances. The only reason I can see for such a development would be the provision of low-cost affordable housing. However this area is eminently unsuitable for low-cost housing for the following reasons: 1. The site is 4.6 miles by road from the nearest town of Leamington Spa. 2. There are no shops in either village. 3. There is only a skeleton bus service. 4. At least one and preferably two cars per family are required to access necessary amenities. 5. There would greater demand for affordable housing in areas closer to town and suburban amenities. In addition, the site is unsuitable for building development for the following general reasons: 1. The site is too large and with too many potential dwellings to be sustainable in this rural location. 2. The cost of providing extra amenities would be too great. 3. There is insufficient primary school provision, the nearest being a small school in Cubbington. 4. It is close to the new HS2 line which is already scarring the landscape. 5. The River Leam close to the Red Lion pub in Hunningham floods regularly and has caused significant damage to housing, one or two properties now being uninsurable.

I write to express objection to propped sites in Ashow - one for light industrial use opposite Dial House Farm and the other ten (+) residential properties off Grove Lane. Ashow is a beautiful, unspoilt, very small village which deservedly enjoys the protection of being in the green belt and in a conservation area. I believe there needs to be exceptional circumstances to justify building on green belt and none have been presented. The plot of land in question sits outside of the village boundaries, so does not qualify for infill consideration, and is in a conservation area that the council itself has identified (Ashow Conservation Area report) as especially important to preserve the character of the area. There is no mains drainage in Ashow and there are only 2 roads - one of which is very narrow, steep road with no space for a pedestrian footpath or street lighting and with no turning circle at the end which cause congestion and difficulties turning already, particularly for deliveries / oil tankers / horse and sheep trailers etc. There are no bus routes to the village and no continual footpaths to Leamington or Kenilworth. Children attending local schools are being taxied to school, already at the cost of the taxpayer. A Paper was prepared to support the proposals for housing allocations in villages, as set out in the 2016 Local Plan Modifications. This work analysed each of the main rural settlements in the district according to their current population and settlement size, service availability and accessibility. This was used to identify those villages which provide the most sustainable locations which can support, and potentially benefit from, some development. Specifically this analysis generated a score for each settlement which allowed villages to be classified in the Local Plan as follows: The highest score was Hampton Magna with 57, and, more locally, Leek Wootton with 38, Stoneleigh with 25, and Ashow with a minimum score with Blackdown of 16. (1) I request that the proposed development of 10 houses offered to the Council in Ashow is not accepted as part of the go forward Housing Plan following the Council's request for land to be identified for housing or other uses. The site identified is outside the "Village Envelope" and any infill development needs to be within the village boundary and should be based upon housing needs. We have 2 houses in the village currently for sale that have not been sold despite being on the market for over 6 months, so there is not any genuine housing need and we should not have to continually defend planning applications for it going forward which will be costly for the local authority and probably a waste of taxpayer's money when the site is properly assessed as totally unsuitable. (2) I request that the development of light industrial units opposite Dial House Farm is not accepted as part of the go forward Housing Plan following the Council's request for land to be identified for housing or other uses. There is no one unemployed in Ashow village that requires employment. Also any development generally out of Leamington towards Kenilworth means that the countryside and green belt between the towns will be lost. It will end up like Leamington - Warwick where there is no green boundary now at all between the towns. We live in the countryside but there are fewer and fewer areas for rural activities - horse riding / basics such as walking the dog through pleasant countryside which was so important for everyone's mental health during Covid. People living in Kenilworth and Leamington town centres love to walk to our village as it is a pleasant country walk within easy reach to them – and accessible without need of a car, with a lovely village club open to serve tea etc half way.

Q S1: Strategic Green and Blue Corridors South Warwickshire Councils need a clear policy to protect important environmental assets, designated and non-designated sites including potential local wildlife sites. As well as a policy to enhance and restore wildlife sites. Without watering down the policy with wording such as ‘where appropriate’ and in line with the priorities of the Biodiversity Action Plan. The Councils need to plan in line with the legal requirements set out in the National Planning Policy Framework (NPPF), 25 year Environment Plan, the Government’s commitment to 30% land in nature recovery by 2030, COP 27 and COP 15 and the Councils declared climate change emergencies. National Planning Policy Framework Paragraph 20d) requires ‘conservation and enhancement of the natural environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation’ Paragraph 175. Requires Councils ‘take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries’. QS1a Yes this should study be produced in advance of the Nature Recovery Network, as it is a very important bit of local work and needs to inform ‘Sound’ locations of growth. This is also a legal requirement in the NPPF. The 2013 Green Infrastructure study is also now 10 years out of date, and considered very outdated. This needs to be reviewed early on and in detail, in order to deliver joined up habitats and influence the spatial options. This should be produced based on Natural England’s new GI Framework Green Infrastructure Home (naturalengland.org.uk) The Nature Recovery Strategy will also take some time to produce, so we need a policy in the interim.

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: It is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 – Rail Corridors. The prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. Development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding areas and stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.1: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire. I am concerned that the plan hasn’t considered local biodiversity in enough detail in their growth strategies, with a number of growth areas directly adjacent to the important River Avon and River Leam and their tributaries. As well as a number of key Local Wildlife Sites. The Councils also urgently need to assess their ‘Potential Local Wildlife Sites’ to give them more weight, especially in the south as these should have full LWS status and should be informing the growth strategy. I am particularly concerned that the ‘Dispersal option’ includes a number of large settlements actually in the Area of Outstanding Natural Beauty (AONB), this isn’t considered a legally sound Option in line with the Sustainability Appraisal. The NPPF states ANOB should only be considered in exceptional circumstance and Para 76. States ‘the scale and extent of development within all these designated areas should be limited’. I am concerned that a number of important Local Wildlife Sites and Potential LWSs are located in the proposed growth areas, including a number of key SSSIs and the Nature Improvement Area: Leamington- Warwick Racecourse Nursery Wood and Newbold Comyn LWS’s and the Grand Union Canal LWS. Southam- Long Itchington quarry, Bishops Hill and Bishops Bowl LWS, Ufton Hill Farm Fields PLWS Q-S8.1 – Settlements falling outside the chosen growth strategy: A threshold approach to small scale development is not appropriate in greenbelt areas. The plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. 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 believe 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.

The development options of focusing new development on railway, and other transport corridors is supported as it reflects the development strategy in the emerging SWDPR as set out in the 2022 Regulation 19 SWDP Review Publication document. Encouragement is given though to considering how both housing, along with economic development can be woven into this approach from the options set in the consultation. Of direct interest to Wychavon District Council, as previously referred to in the June 2021 consultation is the proposal under the new settlement/rail corridor option titled New Settlement Option E1, Long Marston Airfield. This includes a possible uplift in the number of homes in the locality with a further 3,500 dwellings, in addition to the 3,500 homes planned at the Long Marston Airfield Garden Village. Concern is expressed regarding the impact of this on the Vale of Evesham in terms of traffic, existing road networks and highway capacity, other infrastructure requirements, the environment generally and the heritage assets in particular in Pebworth village. With respect to the latter point these routes through the village are identified as important and valued visual assets in the Pebworth Neighbourhood Plan (2019). Therefore, strong support would be given to any mitigation approaches that include the provision of high-quality public transport links, preferably rail, to/from Long Marston, with a railway station at Long Marston itself. In addition, that the aim to reinstate the railway line from Honeybourne to Stratford continues to form part of the strategic public transport strategy for this plan, including the safeguarding of routes etc. reflecting the position in 2022 SWDPR 06 Publication (Regulation 19) document.

The two sites I would like to strongly object to are Ref 193 land adjacent to field house Ashow For a minimum of 10 residential properties - And ref 195 land east of A46 - light industrial These site are strongly unsuitable for development on basis- Residential plot Increases envelope of the village No public transport to Ashow so would have a significant impact on traffic - 2 to 3 vehicles per house plus deliveries visitors etc No gas or mains sewerage so again impact of lorries delivering oil and emptying septic tanks Road access is single track - can’t handle increased traffic Development is within green belt and conservation area Significant detrimental impact on houses in long row No services within the village - school shop etc therefore increased traffic No housing need identified in the village Industrial plot Green belt land No economic need Historic park land Road access is dangerous - access is only one way at the junction Loss of arable farm land

My name is Steve Edwards, I am currently the chairman of Ashow village. Please accept this email as an official objection to the possibility of 10 house situated behind Long Row and Grove Lane. The access to this field is totally unacceptable for housing development, it is greenbelt land and I see know benefit to the village whatsoever.

The South Warwickshire Local Plan (Issues and Options) area is partially covered by the explosives safeguarding zone that is designated to protect the operational capabilities of the explosives storage and handling facilities at the Defence Munitions (DM) Kineton site. This MOD explosives safeguarding zone extends across parts of the South Warwickshire geographic area, and is within the local authority area of Stratford-on-Avon District Council. The MOD explosives safeguarding area is comprised of two distinct zones, an inner zone bounded by a yellow line and an outer zone bounded by a purple line. The Inhabited Building Distance (IBD) is defined by a yellow line on the statutory safeguarding map, within this safeguarding zone the MOD monitors the management and use of development to maintain public safety and persons living, working, or congregating for long periods of time. The second consultation zone is the Vulnerable Building Distance (VBD), which surrounds the IBD zone and the outer extent of which is defined by a purple line on the statutory safeguarding plan. Within this zone all inhabited buildings need to be deemed as being ‘non vulnerable’ structures. This means they should be of robust design and construction so that should an explosion occur at the MOD explosives storage facilities, buildings nearby will not sustain damage that could cause critical injury to the occupants. Developments and land use that directly support large gatherings of people outside can also be of relevance to the management of explosives safeguarding requirements for this zone. The local plan sets out a number of objectives and policies that are relevant to these safeguarding zones Issue S9: Settlement Boundaries and infill development: The MOD recognises that infill development implemented in accordance with the current and emerging polices relating to this may affect the explosives safeguarding zones surrounding DM Kineton. The MOD has no objection to the implementation of the existing polices in relation to those settlements that occupy the outer explosives safeguarding zone. However, the MOD would wish to be consulted in its capacity as a statutory consultee upon relevant applications for infill development in accordance with the consultation procedures set out in in the Town and Country Planning (Safeguarded Aerodromes, Technical Sites and Military Explosives Storage Areas Direction 2002 (as updated).