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

I am opposing the proposed sites for housing put forward in and around Welford on Avon, most in open countryside. New settlement I’m very concerned with the proposed further development at Long Marston Airfield and Meon Vale. These new settlements are already struggling with lack of affordable and sustainable public transport, which has resulted in traffic congestions in our country roads. The B4632 is already heavily trafficked, and there is no near rail option. There is the danger of coalescing of villages too. I therefore support the Meon Vale Residents Association’s representations.

I wish to register my objection. The north Leamington green belt is important and should be protected. It is high quality agricultural land and should be protected for food security especially in current times. The walkways and walks are used by local people which is important for health of the community. It helps keep green northern gateway to the town. Development is not in line of government policy. The green belt here fulfills all purpose criteria.

Q-S2: Please select all options which are appropriate for South Warwickshire Option S2a: Identify areas considered particularly suited to intensification development, and develop a design code for each character area. Have a policy supporting intensification within these identified areas where it complies with the relevant design code. The Consultation Document makes the case for encouraging intensification of development in South Warwickshire. Intensification is taken to equate to building at higher densities, but also to include factors such as re-using brownfield sites, converting upper floors or building additional storeys to existing buildings, and infill development on existing street frontages. These principles are worthwhile and will contribute to maximising the number of new homes in suitable locations. However, not all locations will be suitable for higher densities or for the other elements of intensification described in the Consultation Document. Much of the plan area is rural and characterised by villages and smaller towns characterised by lower density built form and although there may be opportunities in such locations for intensification, it is likely that design guides and design codes will require a form of development more complementary to the existing. Additionally, higher density developments of the kinds described will create new homes in more urban areas – but these are not likely to meet the needs of all groups in society across South Warwickshire, and will be mostly located in existing larger towns therefore not meeting the needs of residents of rural areas. A blanket approach to intensification across South Warwickshire would be likely to lead to an unbalanced spatial strategy not able to meet identified needs of all groups in society. However, an approach which identifies where intensification could take place as part of a balanced spatial strategy, with a carefully constructed design code to guide the form of development could be very successful, and this option is therefore supported. Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: The Consultation Document sets out Spatial Growth options. These set out high level broad approaches to accommodating growth across South Warwickshire which are also subject to analysis in the Sustainability Appraisal. Each of these options, alongside the issue set out at Issue S5 which examines the potential for new settlements, seem appropriate options for approaches the SWLP could adopt to develop a strategic approach to accommodating growth. Using any of the approaches as a strategic principle for accommodating significant levels of new housing to meet needs would seem to have merit – the determining factors would clearly come down to whether sufficient sites could be found under each option to accommodate the identified levels of housing need – as set out above. It is unfortunate that the Consultation Document seems to offer these options as ‘either/or’ choices, with the Q-S7.2 question asking whether each option is an appropriate strategy. We would suggest that each option is an appropriate strategy, but that it seems unlikely that any one option in isolation will be able to accommodate all housing needs and also represent a sustainable spatial strategy that will achieve the strategic objectives set out earlier in the Consultation Document. A spatial strategy which combines several of the approaches set out in Options 1 – 5 would seem to be the most appropriate solution to take forwards. For example, it would seem sensible that an approach based on new settlements, could also then look to accommodate strategic growth at locations well served by sustainable transport options and close to existing and future employment opportunities. Such an approach could also include an element of a dispersed strategy, picking up on the opportunities outlined earlier to create networks of rural villages which could provide services for the more dispersed population of South Warwickshire and provide limited opportunities for growth in appropriate villages. In particular, Option 5 looking at dispersed development should not be dismissed. As a stand-alone strategy, it would seem right that such an approach would not be able to accommodate the levels of growth required without significant sustainability issues as set out in the accompanying Sustainability Appraisal. However, as part of a spatial strategy which sought to accommodate strategic levels of growth in new settlements and at existing, well connected larger settlements, and which also directed an element of growth at rural villages with a level of services which enabled them to form sustainable rural networks – an element of dispersal could work effectively to support rural communities. Such an approach would simply build upon and evolve the principle set out in the Stratford-on-Avon Core Strategy of directing a certain amount of hew housing to Category 3 settlements such as Ettington – to enable them to grow sustainably and continue to provide facilities to the surrounding rural population. Issue S9: Settlement Boundaries and infill development The Consultation Document sets out that both the Stratford-on-Avon Core Strategy and the Warwick Local Plan set out settlement boundaries for some or all of the settlements in their area, and that they establish where new non-strategic small-scale development may be appropriate within the confines of existing settlements. Two options are proposed, offering two different approaches to setting settlement boundaries in the SWLP. It is unfortunate that there is not an option for removing settlement boundaries altogether and using a more nuanced and sensitive approach to assessing the appropriate-ness of development within and adjoining settlements in South Warwickshire. Settlement boundaries are inevitably drawn tight to the built form of settlements and are set out as an absolute limit to development, with any proposals beyond the boundary assessed as being in open countryside, even if the site is contiguous with the settlement, close to existing facilities and represents clear rounding off. In these circumstances, perfectly sustainable proposals for development may be assessed as inappropriate simply by virtue of being on the wrong side of an arbitrary line. In the most unfortunate examples, a settlement’s opportunity for modest growth which would sustain services and enable local people to find homes in their community can be thwarted by a settlement boundary. We would suggest that settlement boundaries are not carried forward into the SWLP. Other policy approaches are used in other parts of England which enable judgements to be made on a case-bycase basis, with reference to the status of a settlement in the settlement hierarchy – which we note is already in existence for Stratford-on-Avon as set out in the Core Strategy Policy CS.15. An example of an approach which would be very successful in South Warwickshire can in fact be found in the Local Plan of the neighbouring West Oxfordshire District Council, which applies an infill and rounding off policy to its settlement hierarchy without reliance on settlement boundaries. This approach has allowed for a nuanced approach to village development in very sensitive landscape settings, which has led to highly successful developments in appropriate locations for many years and has been continued in successive local plans.

I write to express my opinion as a long time resident of over 24 years in Wootton Wawen to the proposed plan of building up to 500 houses around the town. Whilst I do not in away object to the obvious need to build more houses particularly affordable ones for younger families, I do not want to see any development without serious consideration being given to major improvements to the overall infrastructure. In terms of the proposed 500, I feel it should be more in the region of 150. However the following points need to be addressed:- Why are we allowing further development on green belt and eroding our laid out boundaries? This is my main objection. There are insufficient trains and buses throughout the day and evening to cope with an increased population. The doctors surgery in Henley is at full capacity already with great difficulty in obtaining appointments. The Pharmacy in Henley is the nearest and the worst in the area with very poor stocks. The roads cannot cope with traffic at the moment and speeds along the Alcester Rd for example are uncontrolled. The is no mains gas in the village at all. Can the water and sewerage cope with increased demand? Does the fire station in Henley need to be manned more permanently to protect the increased population? 500 houses is far too many and 10-150 is more reasonable but not before the infrastructure is improved to cope.

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.

Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. I am specifically opposed to development of land in the greenbelt areas 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. The first development should be Brown field and only then should Green field sites be considered

Q S.1 Please select the option which is most appropriate for South Warwickshire Option Claverdon supports option S1a. It is essential that Claverdon has a role in identifying areas in the green belt and green spaces which are proposed to be released for development or retained in green corridors. Q S.5.1 Please provide any comments you have on the emissions estimation modelling for the seven potential new settlement options. Claverdon does not have access to the competences that would enable it to respond to this question meaningfully. Q S5.2 Do you think new settlements should be part of the overall strategy? It is essential that the SWLP sets out how these facilities will be provided. Infrastructure must precede development. Q S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: Claverdon would need to see options which are better defined, more granular and phased in shorter periods because a successful plan is very likely to be a mixture of all of the development options set out. Three of the five criteria are tied up with transport and connectivity, but transport and other links are not binary factors. 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? Outside the settlements the Countryside Policy should prevail. Inside the settlements the size should be in accordance with the Neighbourhood Plan and appropriate to the nature of the specific sites 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? Outside the settlements the Countryside Policy should prevail. Inside the settlements the size should be in accordance with the Neighbourhood Plan and appropriate to the nature of the specific sites. Q S.10 Please add any comments you wish to make about the development distribution strategy for South Warwickshire. Claverdon simply reiterates that the associated plan infrastructure is inadequate

Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that, in addition to the existing evidence base studies, additional technical studies will be commissioned to inform the SWLP including a Green Belt study. There are, however, a number of non Green Belt settlements in the plan area that are suitable for an allocation. Salford Priors is located outside of the Green Belt. As detailed within these representations it is a sustainable location for development. BTL control land at Bomford Way, to the north of Salford Prior, that is ideally suited to residential development. As detailed in our Call for Sites submission is a readily deliverable housing site that should be preferred location for residential development.

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 that require a complete infrastructure package will take several years to deliver following adoption of the SWLP. They must, therefore, be supplemented by other allocations, especially for the early delivery of new homes. Q-S5.3: Growth Option 1 – Rail Corridors, is an effective Growth Option that will enable South Warwickshire to both deliver new housing and which will meet the SWLP’s sustainability aspirations. Its effectiveness in delivering sustainable development would be enhanced when considered in combination with other growth scenarios, including bus services and the provision of employment. Development is required at the larger villages in the Plan area, such as Salford Priors, to meet their growth requirements and to support their services and facilities. Q-S9: If reviewing the settlement boundaries is delayed until the part two plan it will stifle housing delivery in sustainable locations to the detriment of the plan’s strategy. As a consequence, any part one plan should clearly indicate the settlements that will be expected to accommodate additional growth and a broad indication of the level of the growth.

QS4.1 Growth of existing settlements – Growth of existing settlements should be considered only 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. 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 identifiable exceptional circumstances for 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 brownfield or other non-greenbelt land. There are ample non-greenbelt options for new settlements. Q-S7.2 – For the remaining spatial growth options, I feel the need for greenbelt development in each spatial option should be carefully considered before selecting a specific spatial growth option. This is required to fulfil the 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 an alternative spatial growth option could be selected that requires less (or no) greenbelt development, and the option with the least greenbelt development should be selected, even if additional infrastructure work is necessary as this will still be less than the infrastructure work required for greenbelt developments. Claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. 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 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 and could aggravate the Climate Emergency. This does not meet the requirement statement to deliver “a biodiverse and environmentally resilient South Warwickshire – strengthening green and blue infrastructure and achieving a net increase in biodiversity across South Warwickshire”.

Q-S8.2: suggest we need some evidence base for the number Q-S10: Need to take action now

I do not feel a threshold approach to small-scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small-scale growth developments to come forward in greenbelt areas. I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

2.2.2 1.4 of the I&O documents states that: “Part 1 of the Plan will establish a robust and flexible framework which will set out where and how much development should take place across South Warwickshire.” At present the strategy (and associated optioneering) appears too focused on the main towns and needs to include other settlements within the plan area – reflecting the polycentric nature of both districts, in order to ensure that rural communities, equally with urban communities, can become more sustainable in the future. 2.2.3 As noted above, Paragraph 11 of the NPPF highlights the need for plans to promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects. To comply with paragraph 11 of the NPPF, the SWLP needs to provide a comprehensive spatial strategy that seeks to: meet the development needs of the whole area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects. In relation to the spatial strategy the I&O document is too limited in scope and overly focused on the main towns. It is also crucial that the Part 1 Plan provides a coherent strategy for LP2s and updates to Neighbourhood Plans, rather than leaving it to Part 2 Plans to establish the strategy. The Adopted Stratford Core Strategy states (quoting the former Commission for Rural Communities: “Our challenge is to chart a course by which rural communities, equally with urban communities, can become more sustainable in the future”.

Green belt considerations 2.2.7 It is noted that the I&O document states at page 58 that, at this stage, the spatial growth options are presented with Green Belt policy “off.” 2.2.8 The vision and spatial objectives should be clear that the principle of the Green Belt remains, and it will continue to shape new development, especially with regard to its fundamental aim of preventing urban sprawl by keeping land permanently open (NPPF paragraph 137). The key purposes of preventing sprawl and merging of settlements (NPPF paragraph138) is a critical issue on the fringes of the Greater Birmingham conurbation and Coventry. Paragraph 141 of the NPPF states: “Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.” (emphasis added) 2.2.9 The sequential approach to the consideration of locations for growth should also be reflected in the evaluation of the growth options. This applies to consideration of sites for need arising within the districts and any shortfall arising from outside of South Warwickshire (referenced at QH4-3). Any future consideration of spatial options should therefore include a Green Belt policy “on” appraisal.

I cannot lose this opportunity to strongly make three other points - 1. Proposals for sites for development which I have seen place great emphasis on development on Green Belt land and this should be resisted at all costs. I used to say that the gap between Leamington and Kenilworth was 10 fields. With development of housing in the south of Kenilworth, this has already been reduced. 2. I am concerned about how many people who buy houses in Warwick actually work in the proximity of their homes. I recognise the increase in home-working, but even so policy makers should be aiming to reduce commuting for several reasons - to reduce pollution for health reasons, to reduce carbon emission for climate reasons, to reduce the need for more road-building and to conserve energy resources. 3. I note that the proportion of rural land remaining in Warwick District is much less than that in Stratford District. May I suggest that location of development should take this into account.

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.

QS4.1 Growth of existing settlements Infrastructure can be built to support the growth of existing settlements without needing to develop upon green belt land. Q-S5.2 - New Settlements The principles of the National Planning Policy Framework include an environmental objective – to protect and enhance our natural environment; including making effective use of land, improving biodiversity, and using natural resources prudently. I do not believe that any exceptional reason has been made successfully to warrant development on green belt land. Q-S5.3 – Rail Corridors Rail corridors would be an ideal choice for development without needing to use green belt 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 green belt areas. I do not believe the Local Plan should permit small scale growth developments to come forward in green belt land. Q-S10 – Any other comments There are detrimental impacts upon small villages such as Weston Under Wetherley where dispersed housing development changes the rural character. I am specifically opposed to development of land in the greenbelt areas in and around Weston under Wetherley, Hunningham, Wappenbury and other similar small green belt villages due to the impact on the rural character of the area of the North Leamington green belt. The Local Plan appears to be using the Climate Emergency as a way to justify development upon the green belt. There are many approaches to mitigating the climate emergency without building on the green belt. The loss of the natural environment clearly does not support Climate improvement. S6 which deals with the review of green belt boundaries doesn’t allow for comment. This issue should not have been included without the option to comment.

Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the green belt

[Rep made by a young daughter] [Redacted Text] I love walking over the fields with my dog and my mummy [Redacted Text]. It feels wonderful to step through the gates of civilization into the fresh open air where I see different crops growing in the sunshine. Nature is so important to us all and to think those beautiful fields will be filled with houses makes me really sad. There will be no more rabbits running to the hedges, no bees flying overhead collecting pollen, no flowers springing up on the edge of the path and no muddy puddles to splash in. It's those things that we will all miss and for those reasons that I ask the council to reconsider plans and reject the proposed developments.

I wish to register my objection to any proposed development on the Green Belt land referred to as “Land at Blackdown, north of Leamington Spa Site 174 within Green Belt Parcel RL2”. This land is a “higher-performing Green Belt Parcel” therefore allowing development in this area would conflict with the purposes of the Green Belt and remove a high-level green belt parcel. The Council’s position set out in the 2017 Warwick Local Plan (and supporting documents) recommended that the Green Belt land (previously referred to as WL 7) now referred to as site 174 following detailed analysis should be excluded from consideration and remain as Green Belt. Warwick District Council’s adopted policy is to apply National Planning Policy to proposals within the Green Belt.The National Planning Policy Framework position on protecting Green Belt was updated in July 2021, and if anything, the arguments for protecting Green Belt, particularly higher-performing Green Belt have strengthened in favour of them remaining as Green Belt. The revised Framework states that the Government attaches great importance to Green Belt. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. The five fundamental purposes of Green Belt are: • to check unrestricted sprawl of large built-up areas; • to prevent neighbouring towns from merging into one another; • to assist in safeguarding the countryside from encroachment; • to preserve the setting and special character of historic towns; and • to assist in urban regeneration by encouraging the recycling of derelict and other urban land. The Framework further states that once established Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. That local planning authorities should plan positively to enhance their beneficial use and that inappropriate development should not be approved except in very special circumstances. I strongly believe that site 174 with an established well defined boundary on the northern edge of Leamington Spa clearly meets the first four of the five fundamental purposes of Green Belt as set out above, and that the exceptional circumstances necessary to alter the Green Belt covering site 174 cannot be fully evidenced or justified. The Green Belt land referred to as site 174 should thus remain as Green Belt.

I would like to register my objections to encroaching on the green belt north of Leamington at Blackdown and Milverton. The approach to Leamington from the south has already been ruined by extensive development on our beautiful Warwickshire countryside. Where are the secondary schools and hospitals to cope with this influx of people? The countryside between Leamington and Kenilworth is our last remnant of rural landscape. PLEASE DONT SPOIL THAT TOO. There are derelict buildings in Leamington that could be used for development including what was the milk marketing office on the Kenilworth road which has been empty for the last fifty years, and the site of the retirement home on the Lillington road Which is now closed.

2.5 The Role of New Settlements in Meeting Future Needs (S5.2 and S5.3) 2.5.1 New settlements could have a role in helping to meet future needs but there is a need to ensure that they form part of a coherent spatial strategy for the whole plan area, are in sustainable locations, are deliverable, viable and will contribute to housing land supply over the plan period. 2.5.2 The options considered include several locations that are presented as new settlements. These all appear to have been appraised on the basis that they could provide up to 6,000 dwellings. As information has not been provided on the sites it is not clear if this assumption about the capacity of the identified locations is appropriate and therefore whether or not development on this scale represents a reasonable alternative at each location. The assumptions about the capacity of sites promoted by landowners/developers should be made clear in the evaluation of any location. Any revisions to the assumptions about new settlements as a source of supply should be reflected in the Sustainability Appraisal. 2.5.3 Paragraph 68 of the NPPF states (our emphasis): “Strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.” 2.5.4 The above emphasises the need to consider locations for growth that are developable. To be considered developable, sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged, Annex 2 of the NPPF. 2.5.5 Any proposals for new settlements that are taken forward into the Local Plan will also need to demonstrate compliance with paragraph 73 of the NPPF, which requires new settlements to be “well located” and “supported by the necessary infrastructure and facilities (including a genuine choice of transport modes)”. Paragraph 73 of the NPPF goes on to state that Councils should “identify suitable locations for such developmentwhere this can help to meet identified needs in a sustainable way” through considering “opportunities presented by existing or planned investment in infrastructure”. 2.5.6 Paragraph 73 of the NPPF states that policies for new settlements should “ensure that appropriate tools such as masterplans and design guides or codes are used to secure a variety of well-designed and beautiful homes to meet the needs of different groups in the community”. 2.5.7 Paragraph 106 of the NPPF requires planning policies to be prepared with the active involvement of local highways authorities and other transport infrastructure providers and operators so that strategies and investments for supporting sustainable transport and development patterns are aligned. 2.5.8 The Inspector for the examination into the Tunbridge Wells Local Plan raised concerns around the treatment of large scale strategic allocations in the submitted Local Plan in his initial findings. 2 The Inspector raised concerns regarding the adequacy of the evidence base in relation to the new settlement at Tudeley Village (new settlement of 2,800 dwellings), as well as in relation to aspects of the growth at Paddock Wood (3,500 homes and 11 ha employment). 2.5.9 In relation to Tudeley Village the Inspector highlighted the need for the Local Plan evidence base to include additional information in relation to infrastructure requirements, including funding and phasing and the relationship between delivery rates and viability. 2.5.10 In the absence of this information the Inspector concluded that the Local Plan required modification to make it sound and capable of adoption. He also concluded that providing additional information in relation to Tudeley Village would not be a quick or a straightforward exercise. Modifying the policy could also add significant delays to the examination process. The third option he presented was to delete the allocation and make consequential changes to the Local Plan. 2.5.11 Similarly, the Inspectors Report into the Shared Strategic Local Plan for North Essex 3 concluded in relation to the Garden Community proposals that they need demonstrate a reasonable prospect of being viably developed, setting out clear details of phasing of necessary infrastructure linked to a delivery timetable and that any garden community proposals must be clearly shown to be financially viable. 2.5.12 Supplementary Planning Documents (SPDs) are sometimes seen as a mechanism for resolving matters associated with planning for new settlements. While SPDs have a potential role in helping to bring sites forward they cannot allocate land for development, as an SPD does not form part of the development plan, which means that decisions around the location of a local centre, employment or other specific uses will need to be made as part of Local Plan preparation so that these can be identified on the Local Plan proposals map. 2.5.13 Where options for new settlements are taken further the assessment of sites should also consider likely lead in times and anticipated delivery rates and how these will impact on the delivery of housing, particularly during the earlier stages of the plan period – the Lichfield Report (From Start to Finish)4 includes an analysis of delivery rates and a rate of 160 homes per annum is typical for sites over 2,000+ homes. The report highlights the significant lead in times that can be associated with larger development (i.e. sites of over 500 homes) from the date at which an outline application is validated, the average figures can be 5.0 to 8.4 years for the first home to be delivered. 2.5.14 Question S5.3 asks specifically about rail corridors as a location for growth. This approach to spatial development is considered too simplistic and might not necessarily lead to a more sustainable development strategy over alternatives. This is because not all settlements that are currently served by rail are located in accessible locations for non-rail based movements. Furthermore, not all of these settlements currently have existing services, social and community facilities etc and therefore would only be a sustainable location for growth if major development was focused at such settlements with requisite supporting infrastructure. It is considered best to have a blended spatial strategy and if rail represents a viable option implement this in a staged way over more than one Local Plan period. 2.5.15 Any development adjacent to an existing railway station that requires expansion of rail facilities will also clearly have to demonstrate that issues around viability and deliverability of new rail related infrastructure have been addressed. Network Rail is the licenced, regulated manager of the rail network, its guidance clearly and repeatedly states the need for, and benefits of, early engagement with industry, including Train Operating Companies (TOCs), Rail Freight Operating Companies (FOCs), Department for Transport (DfT) and other industry stakeholders. Any such matters would be potentially complex but would need to be satisfactorily resolved prior to submission of the Local Plan because they fall under the duty to co-operate. 2.5.16 All of the above highlights the importance of the Local Plan front loading relevant issues and the associated evidence base in relation to the delivery of any new settlements that are included in the SWLP, particularly of the scale envisaged, even if delivery is envisaged later in the plan period. 2 https://forms.tunbridgewells.gov.uk/__data/assets/pdf_file/0007/434392/ID-012-Inspectors-Initial-Findings.pdf 3 https://www.braintree.gov.uk/downloads/file/2940/examiners-report-on-the-examination-of-nea-s1-10th-dec-2020 4 https://lichfields.uk/content/insights/start-to-finish

2.6.1 It is noted that some smaller settlements have been considered as part of the technical work for some of the growth options but not Harbury. 2.6.2 The spatial strategy options considered are: 1 - Rail corridors 2 - Sustainable travel (rail and bus) 3 - Economy 4 - Sustainable Travel and Economy (hybrid of the new 2 and 3) 5 - Dispersed 2.6.3 Having refined the spatial growth options, the Councils then identified settlements for consideration under selected spatial strategy options. Settlements for initial assessment were identified by the Councils on the basis that they fell within the first or second tiersettlements within either the Stratford on Avon District Core Strategy (‘Main Town’ and ‘Main Rural Centres’) or the Warwick District Local Plan (‘Urban Areas’ or ‘Growth Villages’) and are relevant to more than one of the refined spatial options identified by the Councils. 2.6.4 A key stage in developing a truly joint Local Plan that achieves consistency of approach across South Warwickshire (a key aim of preparing a joint local plan) would have been to revisit the classification of settlements across both districts using a common set of criteria. Given the desire to achieve consistency of approach across the area it is suggested that the update to the evidence base includes a review of the settlement hierarchy across both districts to see if/how they align and to address any inconsistencies. 2.6.5 Harbury, with a population of 2,420 (2011 census) is of equivalent size to some of the settlements that are included in the I&O document) and is considerably larger than others, for example Bearley (population of 724 as of 2011). Harbury is well located in relation to Leamington/Warwick and the Core Opportunity Area for employment that is identified in the I&O document. It has a good range of services and reasonable public transport links with scope for enhancement. Harbury could contribute to growth under either Option 2 or4 for example. 2.6.6 Paragraph 69 of the NPPF also notes that: “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” 2.6.7 Growth of existing settlements should be part of the overall strategy (S4.1). Harbury should be considered in future updates to the evidence base as a location that could contribute to growth associated with options 2 and 4.

Threshold approach (S8.1, S8.2) 2.6.8 Site capacity should be optimised, rather than artificially capped. The scale of development should reflect other factors, including its size, location and development potential – reflecting its relationship to the existing settlement, topography, heritage, ecology, flood risk etc.

Settlement boundaries (S9a and S9b) 2.6.9 Where a site is considered strategic, the SWLP should amend the settlement boundary, rather than relying on LP2s or NDPs, which could lead to delays in sites coming forward and development being delivered in a timely way to meet need. Any allocation would also need to be suitably developed to demonstrate that it is deliverable/developable. 2.6.10 Question S9b asks if the SWLP should review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. We suggest that this exercise is undertaken as part of an overall review of the approach to the classification of settlements to achieve a consistent approach between the two districts. A consistent and suitably evidenced settlement hierarchy is an essential element of a Joint Plan.

The development distribution strategy for South Warwickshire (S10) 2.6.11 As noted elsewhere in this response, the distribution strategy should include consideration of the role of other settlements. As currently proposed, the Part 1 plan is effectively the core strategy with the Part 2 plan allocating non-strategic sites. 2.6.12 The Part 1 plan needs to set the strategic context for such allocations. The settlement hierarchy from the adopted local plans have simply been rolled forward – these should be reviewed to see if they still reflect the position of settlements within the hierarchy or their ability to grow and become more sustainable plus, as it is a joint plan, to ensure consistency of approach between both districts.

1.0 Introduction 1.1 This representation statement has been prepared in response to the South Warwickshire Local Plan Issues and Options Consultation January 2023 on behalf of Border Holdings (UK) Ltd. 1.2 The representations are made in the specific context of the land at Manor Fields Farm, to the South East of the A46, in Stoneleigh which is being promoted as an employment allocation. 1.3 As part of the Call for Sites exercise that took place in May / June 2021 the Manor Fields Farm site was originally submitted as a proposed housing site (Site Reference 33). However, the company withdrew the site as a proposed housing option in December 2021. In response to the continued rise in national importance of freight and distribution land and the importance the Government attaches to catering for good sites to support growth, the company is promoting the site for employment use (now identified under Site Reference 366). 1.4 The site forms part of a larger landholding being promoted to support the expansion of Kingswood Business Park and is known as Stoneleigh Park Expansion Land (Site Reference 99). Border Holdings support the proposed employment site option put forward by Kingswood Business Park which includes the Border Holdings land. 1.5 The site at Manor Fields Farm lies to the north west of Stoneleigh and immediately to the east of Kings Hill Park which is a strategic urban extension site to the south of Coventry. The site is also proximate to a new access onto the A46 Trunk Road providing excellent connections with the strategic highway network. Stoneleigh Park lies to the south of the site. 1.6 The site accords with the tests outlined in the National Planning Policy Framework whereby the site is deliverable because:- • It is Available – Border Holdings (UK) Ltd have control over the whole site and therefore it is available now. • It is Suitable – the site is in a sustainable, suitable location which makes the use of existing infrastructure, is proximate to Coventry and Warwick and the strategic road network and is of a size that can support the delivery of large scale logistics and distribution floorspace. • It is Achievable – The site is available now and has no known delivery constraints. 1.7 Alongside this representation statement a site promotion document, indicative masterplan and highways statement have been prepared. These documents should be read in conjunction with this Statement. 1.8 The site promotion documents demonstrate that the site is suitable, available and achievable for employment use and can be supported as a proposed employment allocation as part of the Stoneleigh Park Expansion Land put forward by Kingswood Business Park. 2.0 Site Description 2.1 The Manor Fields Farm site is currently in agricultural use and lies to the north east of Kenilworth, north west of Stoneleigh and south of Coventry. The site lies to the in close proximity to a new access to the A46 Trunk Road and connection with the strategic highway network. The site is therefore well placed to meet the growing need for logistics and distribution floorspace. 2.2 The site also lies immediately to the east of a strategic urban extension site known as Kings Hill Park which will is proposed to deliver 4,000 new homes and associated infrastructure, which is on the other side of the A42. As part of this scheme, it is intended to create a cycle way and footpath, which will also traverse a further large area of housing, allocated in an existing local plan, via an underpass leading to the subject proposed employment land. There is therefore an obvious synergy between extensive areas of housing and place of work, which will be accessible by means other than the private car. Connecting these areas constitutes sound planning practice. 2.3 The site fronts onto the A46 to the west with the Kings Hill Park site beyond. Agricultural land lies to the north, east and south. Stoneleigh Park lies further to the south of the site. Access into the site would be taken from the east via the B4115 and onto the new A46 junction. 2.4 Whilst the site lies within the Green Belt, opportunities for large scale logistics and distribution development within the settlement limits are rare. Urban extension sites will therefore be required to meet this need. 2.5 The development of the site is achievable. There are no known technical constraints that would prevent the site from coming forward. The site lies within Flood Zone 1 and therefore is at the lowest risk of flooding. An initial Transport Statement has been prepared and demonstrates that access into the site is achievable and there is sufficient capacity within the local highway network to support the development of the site. Conclusion 4.1 This Statement provides comment on the South Warwickshire Local Plan Issues and Options Document. 4.2 Border Holdings (UK) Ltd are promoting land at Manor Fields Farm in Stoneleigh for allocation for employment use (Site Reference 366). The site forms part of a larger landholding being promoted to support the expansion of Kingswood Business Park and is known as Stoneleigh Park Expansion Land (Site Reference 99). Border Holdings support the proposed employment site option put forward by Kingswood Business Park which includes the Border Holdings land. 4.3 We support the identification of Stoneleigh Park as a Major Investment Site and within a Core Opportunity Area in the Issues and Options Document and the proposal to include a policy which directs employment to the Core Opportunity Area. 4.4 The Issues and Options Document does not identify specifically identify Stoneleigh Park as a location for employment land growth on any of the maps which sit alongside the spatial distribution options. Whilst it is identified as an Existing Major Investment Site there is no clear indication that this is also a location where employment growth should be distributed. The expansion of Existing Major Investment sites should be part of the overall strategy, particularly when the site lies within the Core Opportunity Area which is to be a focus for employment growth. 4.5 The Manor Fields Farm site is available for development and is in a suitable location to deliver distribution and logistics floorspace alongside an allocated strategic housing site providing genuinely local employment opportunities. There are no known technical constraints that would prevent the delivery of the site and therefore the site is deliverable. 4.6 The allocation of the Manor Fields Farm site would accrue a number of benefits:- • The site could deliver between circa 45,900 sqm of logistics and distribution floorspace in a sustainable location on the edge of Coventry. • The allocation would contribute to meeting the growing need for large footprint units which are well located to provide access to the strategic highway network. • The site would be readily accessible to the Kings Hill strategic housing site and provide employment opportunities for local residents in a sustainable location. • The development of the site can be accommodated and make effective use of existing infrastructure. • The site can be accessed from the existing highway network and is proximate to the new access onto the A46 Trunk Road. • The site is being promoted for development with a willing landowner as part of the larger Stoneleigh Park expansion land. 4.7 We would welcome discussions with the Councils preparing the emerging Plan to support the allocation and delivery of this site.

I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!).This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt

3. Land off Bush Heath Road, Harbury 3.1.1 In Appendix B we have provided an overview of the Land off Bush Heath Road Harbury (the Site) and details of key development opportunities and constraints that have been considered to inform a concept masterplan scheme design which is also presented. 3.1.2 Harbury is a sustainable settlement served by public transport with an existing range of social and community facilities and services, and therefore a logical location for focusing further development thru the new Joint Local Plan. 3.1.3 The site is available and deliverable, and offers an important opportunity to bring forward new homes to meet local and district needs in a timely way whilst also securing wider community benefits in the form of new POS, new community allotments and dedicated parking for its users and for the adjacent sports pitches.