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

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 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-S7.2 – For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF “exceptional circumstances” principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-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-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.

Q-S 10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire 3.4 The Issues and Options Document sets out 5 different growth options (rail corridors, sustainable travel, economy, sustainable travel and economy, and dispersed). For each of the options an indicative scale of growth is shown for each settlement in terms of dwelling numbers and employment land. 3.5 Each of the proposed options identifies a varying number of locations where new employment growth will be focused. In relation to Stoneleigh Park this is only identified as an Existing Major Investment Site, it is not identified as a site where growth is proposed in any of the options. We suggest this is a missed opportunity. In Chapter 5 of the consultation document the Council is proposing policies which seeks to direct employment growth to the Core Opportunity Area and Existing Major Investment Sites, but this is not duly reflected in the spatial strategy options which only identifies Stoneleigh Park as an Existing Major Investment Site. 3.6 The maps showing the potential locations and scale of growth for each of the 5 spatial distribution options should acknowledge the potential for growth through the expansion of Existing Major Investment Sites. Q-E7: Please select the option which is most appropriate for South Warwickshire Option E7. 1a: Include a policy directing employment to the Core Opportunity Area 3.12 A Core Opportunity Area has been identified which comprises the 5 main towns, the A46 Trans Midlands Trade Corridor and the central section of the M40 along with the University of Warwick’s two campuses, Long Marston Garden Village and Rail Innovation Centre, Stoneleigh Park and the automotive hub at Gaydon. 3.13 The Core Opportunity Area looks to attract inward investment to drive the South Warwickshire economy as well as encourage inward investment in the most accessible parts of South Warwickshire. 3.14 Major Investment Sites within the Core Opportunity Area include the Stoneleigh Area and Stoneleigh Park. 3.15 The supporting text highlights that the Stoneleigh Park site will be significantly impacted by HS2 and this provides an opportunity to reassess the use and purpose of the site and the density of development within it. 3.16 It is also stated that there is also a potential opportunity for a new site access stemming from the new A46 Stoneleigh Junction which would reduce traffic impacts through the village. 3.17 We welcome the inclusion of the Stoneleigh Area and Stoneleigh Park as a Major Investment Site within the Core Opportunity Area and support a policy that would direct employment growth to this area. Q-E7.2 – Please select the option which is most appropriate for South Warwickshire Option E7.2a: Include a policy relating to additional economic growth at the major investment sites 3.18 We would support a policy that seeks to allocate additional land for specific employment uses at the major investment sites including Stoneleigh Park. 3.19 There is increasing national support for well-located distribution sites. Stoneleigh Park, which lies to the south of the Border Holdings site is identified as a Major Investment Site on the South Warwickshire Key Diagram. The site and wider area that is being promoted as an extension to Stoneleigh Park is ideally located to meet the need for logistics and distribution floorspace. 3.20 The site provides an opportunity to support employment growth in a well placed strategic location. The Government’s “Future of Freight Plan” (June 2022) highlights the significant shortage of strategic employment land. Suitable logistics sites need to have close proximity to motorways and major A-roads and be situated away from residential areas. 3.21 The Border Holdings land is ideally placed to meet the needs for strategic employment land for the South Warwickshire Joint Local Plan as well as being optimally located to provide nearby residential areas with employment opportunities which are not reliant on private car use. 3.22 The Manor Fields Farm site is being promoted as part of a larger sustainable strategic employment allocation (Site Reference 99) that will assist the Council in meeting the increasing need for logistics and distribution floorspace in an area where significant new residential development is being delivered.

Option S2-C: Intensification 14. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Rosconn Strategic Land consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 15. 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? 38. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Rosconn Strategic Land agree that a threshold approach would be appropriate for any settlement listed 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? 39. 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.

Q-S1: The JPC supports option S1a It is essential that the community 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 in order to represent its’ wishes in the determination of the SWLP Spatial Growth Strategy .Attention is drawn to the Levelling – up and Regeneration Bill: Reforms to National Planning Policy and the Governments’ intention to amend the NPPF Q-S5.2: Without a significant change to the approach to funding infrastructure none of the options will be adequate. The document correctly identifies that provision of the correct infrastructure must underpin this plan. The plan identifies the importance of effective communications, especially transport. The provision of adequate utility and Internet services is also deemed essential, as are the public services of health, education and welfare. And community facilities and open space? There is nowhere in the document that outlines the way improvements in all of these things are to be undertaken, and whether as part of the SWLP Part 2 the authorities will be approaching the statutory providers and the key private-sector agencies involved in public services to ensure that they will guarantee the investment necessary. This is obviously central to areas like Henley in Arden/Beaudesert and the surrounding villages, which feature heavily in the growth priorities. It is incumbent on SWLP to make a statement as to how these facilities will be provided. Infrastructure will need to be delivered in advance of the development It has happened elsewhere … It would be ludicrous to pretend that the private sector will be able to fill this gap entirely yet this seems to be the assumption behind the plan. Q-S5.3: The SWLP identifies connectivity/transport/communication as the single most important criterion in choosing preferred options. This is not reflected in the analysis within the body of the document. The quality of transport infrastructure is not given sufficient attention in the consultation document. Instead There should be a much more detailed analysis of the quality and usage the road system and rail and bus services in the subregion. No option can be chosen without an assessment of the quality of the services and if and how improvements in those services can be realigned under the growth proposals. The road structure in Henley and Beaudesert has not changed since the 1950’s yet no road proposals affecting Henley Beaudesert are included in the document. Nor is there any mention of necessary and vital improvements to the rail and bus services. This is a crucial omission which needs to be corrected before the preferred option is published. Dissatisfaction was abundantly clear with all aspects of road rail and bus services in responses to the JPC community consultation. Q-S8.1: 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: 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-S10: The JPC has received views from 2-300 residents in the short time available. The community have made it clear that the infrastructure of Henley Beaudesert is seriously inadequate. There is anger about the quality of the road, rail and bus situation which have been wrongly identified as strengths of the town. There are several other serious concerns relating particularly to antiquated drainage and sewage systems and flood hazards. Unless the chosen option presents concrete proposals to deal with these issues in the early years of the plan none of the growth options will be acceptable. (repeat of paragraph SI.4.3)

Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. We are also facing a world population collapse in the next 50 years so development of this type has no reasonable justification. 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.

Introduction 1.1. These representations are made by Pegasus Group, on behalf of Catesby Estates in response to the Issues and Options consultation for the South Warwickshire Local Plan. Catesby Estates have land interests at Oaks Farm, Kenilworth which total 24.8 hectares which are considered to be suitable for residential development of up to approximately 300 homes. 1.2. The site is identified on the Site Location Plan at Appendix A and is on the south western edge of Kenilworth, immediately adjacent to the built-up urban area. 1.3. The Site was promoted through the 2021 Scoping and Call for Sites consultation and is identified on the Council’s interactive map (South Warwickshire Local Plan: arcgis.com) with Site ref: 140, noted as being a residential proposal. 1.4. The detail of the Site is not repeated within these representations but specific comments are made where appropriate to respond to the questions identified in the Issues and Options consultation. Notwithstanding, the Vision Framework for the Site that accompanied the previous consultation is included in these representations at Appendix B. In addition, Catesby Estates have commissioned a Transport Appraisal and Heritage Assessment to support the proposed development of the Site. These are set out at Appendices C and D and referred to within these representations as appropriate. 1.5. These representations have had regard to the published consultation document and questions set out therein, accompanying documentation forming the current evidence base, and the national planning context. 1.6. The tests of soundness that Development Plans need to meet so as to be legally compliant and found sound, are set out in the National Planning Policy Framework 2021 (NPPF), para 35: • Positively prepared – providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; • Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; • Effective – deliverable over the Plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and • Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework. 1.7. These tests of soundness, along with other legal and procedural requirements associated with the Plan-making process provide a contextual framework for these representations. It is noted that the proposed changes to the National Planning Policy Framework published in December 2022 propose to remove the requirement for Development Plans to be ‘Justified’ in order to be found sound. However, at the time of writing and submission of these representations that change has not been enacted and these representations therefore still take this test into account. 1.8. These representations refer directly to the specific questions set out in the Issue and Options consultation document and also respond to the following evidence base documents where appropriate: • South Warwickshire Local Plan Part 1 Stage 2: Issues and Options Consultation, January 2023 • Sustainability Appraisal (SA), November 2022 • Housing and Economic Development Needs Assessment (HEDNA), November 2022 • Urban Capacity Study, October 2022 • South Warwickshire Settlement Analysis, January 2023 • Evolving the Spatial Growth Options – The Story so Far – Topic Paper, August 2022 Summary 9.1. In addition to these representations and those submitted to the previous 2021 Scoping and Call for Sites consultation, and with reference to the guidance in the NPPF, Catesby Estates' land interests on land at Oaks Farm, Kenilworth are suitable, achievable and deliverable for proposed development. Suitability 9.2. The Vision Framework and Masterplan indicates how a scheme of 300 dwellings can be achieved on the site having regard to its constraints and opportunities. 9.3. The site is in a sustainable location and well placed to meet the housing needs of the joint Local Plan with access and enhancements to the site's accessibility being appropriate. 9.4. The site is not subject to any statutory nature or heritage designations and is within Flood Zone 1. 9.5. There are not known constraints which would prevent development of this site. Deliverability 9.6. Catesby Estates are in control of the site and are promoting it as set out within his document. The Site has already been submitted as part of the Call for Sites exercise associated with the 2021 Scoping Consultation and accompanying representations were also submitted. 9.7. Catesby Estates has an excellent track record in the delivery of housing, as set out in Table 1 below: Table 1: Catesby Track Record of Delivery 9.8. A planning application for the development of the site could be submitted immediately should it be allocated for development and the site could deliver 40 dwellings per annum. Availability 9.9. Catesby Estates control this land and are actively promoting it for development. The site is immediately available and could start to deliver housing within the next 5 years. 9.10. Catesby Estates 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 further assessment this can be provided upon request.

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

: 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.

The preamble states that Chapter 4 sets out various options as to how the development needs to 2050 (e.g. infrastructure, jobs and housing) might be met. The approach to doing this is split into two sub-sections covering 15 ‘issues’ across both topics; on relating to ‘Development Requirements’ and the other ‘Development distribution strategy’ for the area. 3.58 Paragraph 16 of the National Planning Policy Framework (NPPF) requires that plans contain policies that are ‘clearly written and unambiguous’. In order to establish a clear and unambiguous plan it is critical that the approach to strategic policies follow a logical process. Whilst the title of this chapter may refer to ‘needs’ scant reference is made here to the nature or scale of development needs that should be addressed in the SWLP. Specifically, there is very little, if any, consideration at the top of the document to the growth needs of the area in terms of the level or scale of growth to be planned for in the SWLP. Instead, after setting out the draft vision and objectives in chapter 3, the IO moves straight into considering issues that have a very limited relationship to the growth needs of the area. RPS would suggest that the five issues identified under ‘Development Requirements’ are generic topic-based factors that do not inform the identification of the growth needs for the area or the requirements or targets that might be necessary to address those needs. It is therefore unclear why these considerations have been given such elevated status at the beginning of the document. 3.59 RPS notes that issues relating to the number of homes and jobs that might be required, and the evidence base to justify the approach, is set out in chapter 5 of the IO document (RPS responds to this under separate questions). Whilst providing some clarity, RPS would suggest that given the importance of setting out the growth strategy (or options at this stage) a more sensible and logical approach would be to consider the issues relating to the overall development needs of the area in quantum terms first, before then moving on to consider what the requirement should be in light of REPORT JBB8692.C8271 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 16 the various ‘issues’ i.e. constraints, as identified here. This then provides a clearer and more logical basis for considering the spatial distribution of growth (and options) considered later on (Issue S7). 3.60 At present, therefore, the way the IO is structured is illogical and confusing and does not help the reader to understand the approach being proposed. RPS therefore recommends that the next iteration of the SWLP is reorganised to provide a clear position on the growth strategy at the outset, including the scale of need and the requirements defined to meet that need. This will provide a coherent basis for the spatial distribution strategy, taking into account the various issues identified.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 2A: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be provided that the development is in a sustainable location or would increase the sustainability of the area. 2B: Prioritise development on brownfield land, incorporating existing buildings into development proposals wherever possible, irrespective of its location. 2C: None of these. 3.13. 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. 3.14. 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 and as set out below a Green Belt review will also be required. Issue S6: A Review of Green Belt boundaries 3.21. 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. 3.22. 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. 3.23. 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. 3.24. 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. 3.25. 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. 3.26. The release of Catesby Estates' land interests at Oaks Farm, Kenilworth would not harm the purposes of including land within the Green Belt as follows: • To check the unrestricted sprawl of large built-up areas – The development would result in an extension to the existing urban area of a scale appropriate to Kenilworth's role as a Main Town, where a defined built-up urban area would be expected. • To prevent neighbouring towns merging into one another – Development would not result in the merging of Kenilworth with any other settlement. • To assist in safeguarding the countryside from encroachment – Whilst the land is currently of a countryside character a strong green infrastructure network and provision of open space would created a robust defensible Green Belt boundary to land beyond. • To preserve the setting and special character of historic towns – Development of the site could be accommodated without harm to the significance of identified heritage assets, as set out in the Heritage Statement undertaken for the Site (see Appendix D) Q-S9: Please select the option which is most appropriate for South Warwickshire Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 3.35. It is considered that a combination of both options may be appropriate for the Joint Local Plan. Where the Plan seeks to allocate land for development for strategic sites as set out at paragraph 1.4 of the Issues and Options document, then reviewing settlement boundaries should be undertaken as part of the proposed site allocation. 3.36. Beyond this, 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.

Q-S2 15. Richborough Estates is aware of the potential changes to the NPPF concerning increasing density of development and protecting the character or areas by not having too greater density of development. 16. Richborough Estates is supportive of intensification of development in the right locations which are generally geographically within the urban areas. However, the consequence of intensification is twofold. First, the nature of the accommodation provided tends to be smaller dwellings, usually flats, rather than providing a cross section of new homes which is easier to achieve on medium/large sites. Secondly, and although design codes are mentioned, the character of the area inevitably changes, if the density of development is higher than the existing urban fabric, especially within suburban areas. 17. In reality, the density of development should be driven by the character of the surrounding area not just an attempt through specific density targets to potentially overdevelop land within urban areas which leads to unattractive developments and housing types of the wrong type. Having said this, there is scope for medium/large sites, especially greenfield sites, to create their own character and be able to accommodate a different density of development from that which prevails in the surrounding area. Q-3.2 18. There is merit in directing growth to previously developed land within the built-up areas for housing purposes but not at the expense of diluting the employment land offer. Having employment opportunities available within urban areas is important to delivering a 20-minute neighbourhood concept. If employment land is lost to housing within the urban areas then all that happens is the future residents have to commute to the new employment allocations on the edges of settlements or, especially for logistics, remote locations adjacent to transport nodes. Q-S5.2 21. NPPF paragraph 72 refers to the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. “Significant” can mean a different scale of growth dependent upon the size of the settlement. However, a balanced approach to the dispersal of growth to range of settlements rather than just directing new development to a new settlement is to be preferred. 22. As has become increasingly evident through the Government’s Garden Communities Programme, the aspiration to deliver new garden communities is laudable but the cost of delivering a scheme is increasingly difficult without significant intervention in the form of financial assistance. Further, a new settlement is often in a more remote location away from existing settlements or seeks to expand a smaller settlement (e.g. Long Marston) but there is the need for investment by the public sector in delivering the services required to support a community (e.g.M40 improvements at Gaydon). As simple points, a school or healthcare building can be built but it requires the people to operate the facility. 23. By reason of the financial and implementation difficulties, which can extend to securing all the necessary land, a new settlement is not a logical or appropriate option for South Warwickshire at this time. Q-S5.3 24. Some growth along the rail corridors provides a sustainable strategy but consideration needs to be given to the scale of any development at particular settlements. For example, although both are suitable to accommodate new homes, the scale of growth at Kenilworth will inevitably be greater than at other settlements because of the level of facilities and services available. 25. Further, with the exceptions of parts of Warwick, Leamington Spa and Stratford upon Avon, the majority of the railway stations within South Warwickshire are associated with smaller scale villages located in the Green Belt and both the lack of facilities and Green Belt policy (especially as proposed to be amended in the NPPF) will act as a constraint to significant growth at these villages. Q-S8.1 33. The opportunity should be taken as part of this Local Plan to consider the growth needs and capacity of individual smaller settlements to accommodate growth. In is context, the approach is directed towards growth at the Category 1 and 2 Local Service Villages as identified in the Stratford upon Avon Core Strategy, including Stockton. Growth at Category 3 settlements and below should be a matter for Neighbourhood Plans.

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. 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 is not a valid justification to develop on greenbelt land. It is a weak and bizarre argument as greenbelt is vital for mitigating climate change with benefits such as tackling air pollution, slowing and reducing the impacts of carbon emissions and providing essential habitats for wildlife. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is also no option to comment on issue S6 within the plan (a review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

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. ts: 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. Finally within the village of Weston Under Wetherley, and surrounding villages, there is absolutely no infrastructure in place to accommodate this size of proposed development.

Q-S1 16. At this stage, reliance should be placed upon the Local Nature Recovery Strategy. Q-S2 17. Richborough Estates is aware of the potential changes to the NPPF concerning increasing density of development and protecting the character or areas by not having too greater density of development. 18. Richborough Estates is supportive of intensification of development in the right locations which are generally geographically within the urban areas. However, the consequence of intensification is twofold. First, the nature of the accommodation provided tends to be smaller dwellings, usually flats, rather than providing a cross section of new homes which is easier to achieve on medium/large sites. Secondly, and although design codes are mentioned, the character of the area inevitably changes, if the density of development is higher than the existing urban fabric, especially within suburban areas. 19. In reality, the density of development should be driven by the character of the surrounding area not just an attempt through specific density targets to potentially overdevelop land within urban areas which leads to unattractive developments and housing types of the wrong type. Having said this, there is scope for medium/large sites, especially greenfield sites, to create their own character and be able to accommodate a different density of development from that which prevails in the surrounding area. Q-3.2 20. There is merit in directing growth to previously developed land within the built-up areas for housing purposes but not at the expense of diluting the employment land offer. Having employment opportunities available within urban areas is important to delivering a 20-minute neighbourhood concept. If employment land is lost to housing within the urban areas then all that happens is the future residents have to commute to the new employment allocations on the edges of settlements or, especially for logistics, remote locations adjacent to transport nodes. Q-S5.2 23. NPPF paragraph 72 refers to the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. “Significant” can mean a different scale of growth dependent upon the size of the settlement. However, a balanced approach to the dispersal of growth to range of settlements rather than just directing new development to a new settlement is to be preferred. 24. As has become increasingly evident through the Government’s Garden Communities Programme, the aspiration to deliver new garden communities is laudable but the cost of delivering a scheme is increasingly difficult without significant intervention in the form of financial assistance. Further, a new settlement is often in a more remote location away from existing settlements or seeks to expand a smaller settlement (e.g. Long Marston) but there is the need for investment by the public sector in delivering the services required to support a community (e.g.M40 improvements at Gaydon). As simple points, a school or healthcare building can be built but it requires the people to operate the facility. 25. By reason of the financial and implementation difficulties, which can extend to securing all the necessary land, a new settlement is not a logical or appropriate option for South Warwickshire at this time. Q-S5.3 26. Some growth along the rail corridors provides a sustainable strategy but consideration needs to be given to the scale of any development at particular settlements. For example, although both are suitable to accommodate new homes, the scale of growth at Kenilworth will inevitably be greater than at other settlements because of the level of facilities and services available. 27. Further, with the exceptions of parts of Warwick, Leamington Spa and Stratford upon Avon, the majority of the railway stations within South Warwickshire are associated with smaller scale villages located in the Green Belt and both the lack of facilities and Green Belt policy (especially as proposed to be amended in the NPPF) will act as a constraint to significant growth at these villages. Q-S8.1 35. The opportunity should be taken as part of this Local Plan to consider the growth needs and capacity of individual smaller settlements to accommodate growth. In this context, the approach is directed towards growth at the Category 1 and 2 Local Service Villages as identified in the Stratford upon Avon Core Strategy. Growth at Category 3 settlements and below should be a matter for Neighbourhood Plans. Q-S9 36. Settlement boundaries will need to be reviewed to accommodate development.

Q-S1 16. At this stage, reliance should be placed upon the Local Nature Recovery Strategy. Q-S2 17. Richborough Estates is aware of the potential changes to the NPPF concerning increasing density of development and protecting the character or areas by not having too greater density of development. 18. Richborough Estates is supportive of intensification of development in the right locations which are generally geographically within the urban areas. However, the consequence of intensification is twofold. First, the nature of the accommodation provided tends to be smaller dwellings, usually flats, rather than providing a cross section of new homes which is easier to achieve on medium/large sites. Secondly, and although design codes are mentioned, the character of the area inevitably changes, if the density of development is higher than the existing urban fabric, especially within suburban areas. 19. In reality, the density of development should be driven by the character of the surrounding area not just an attempt through specific density targets to potentially overdevelop land within urban areas which leads to unattractive developments and housing types of the wrong type. Having said this, there is scope for medium/large sites, especially greenfield sites, to create their own character and be able to accommodate a different density of development from that which prevails in the surrounding area. Q-3.2 20. There is merit in directing growth to previously developed land within the built-up areas for housing purposes but not at the expense of diluting the employment land offer. Having employment opportunities available within urban areas is important to delivering a 20-minute neighbourhood concept. If employment land is lost to housing within the urban areas then all that happens is the future residents have to commute to the new employment allocations on the edges of settlements or, especially for logistics, remote locations adjacent to transport nodes. Q-S5.2 23. NPPF paragraph 72 refers to the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. “Significant” can mean a different scale of growth dependent upon the size of the settlement. However, a balanced approach to the dispersal of growth to range of settlements rather than just directing new development to a new settlement is to be preferred. 24. As has become increasingly evident through the Government’s Garden Communities Programme, the aspiration to deliver new garden communities is laudable but the cost of delivering a scheme is increasingly difficult without significant intervention in the form of financial assistance. Further, a new settlement is often in a more remote location away from existing settlements or seeks to expand a smaller settlement (e.g. Long Marston) but there is the need for investment by the public sector in delivering the services required to support a community (e.g.M40 improvements at Gaydon). As simple points, a school or healthcare building can be built but it requires the people to operate the facility. 25. By reason of the financial and implementation difficulties, which can extend to securing all the necessary land, a new settlement is not a logical or appropriate option for South Warwickshire at this time. Q-S5.3 26. Some growth along the rail corridors provides a sustainable strategy but consideration needs to be given to the scale of any development at particular settlements. For example, although both are suitable to accommodate new homes, the scale of growth at Kenilworth will inevitably be greater than at other settlements because of the level of facilities and services available. 27. Further, with the exceptions of parts of Warwick, Leamington Spa and Stratford upon Avon, the majority of the railway stations within South Warwickshire are associated with smaller scale villages located in the Green Belt and both the lack of facilities and Green Belt policy (especially as proposed to be amended in the NPPF) will act as a constraint to significant growth at these villages. Q-S8.1 35. The opportunity should be taken as part of this Local Plan to consider the growth needs and capacity of individual smaller settlements to accommodate growth. In this context, the approach is directed towards growth at the Category 1 and 2 Local Service Villages as identified in the Stratford upon Avon Core Strategy. Growth at Category 3 settlements and below should be a matter for Neighbourhood Plans. Q-S9 36. Settlement boundaries will need to be reviewed to accommodate development.

I would like to echo the comments of Councillor Bill Gifford (included below) with regards to the SWLP. The importance of green belt cannot be understated and it is already at risk in other areas of the county. We must do more to protect and value our countryside, agricultural land and local environment. Response from Bill Gifford - As one of the Leamington Milverton District Councillors, I must express my concern that the Green Belt is not given sufficient weight in the Issues and Options Consultation on the South Warwickshire Local Plan. In my opinion and that of many others, the Green Belt around the North of Leamington fulfils the purpose of Green Belt land. The five stated purposes of Green Belt land are to: 1) Check the unrestricted sprawl of large built-up areas 2) Prevent neighbouring towns merging into one another 3) Assist in safeguarding the countryside from encroachment 4) Preserve the setting and special character of historic towns 5) Assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The Government has recently made it clear in a letter from the Secretary of State for LevellingUp, Housing and Communities, that local planning authorities such as Warwick District Council are not expected to review the Green Belt to deliver housing. Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is to quote the letter from Michael Gove MP is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The Green Belt around North Leamington is recognised as a genuine constraint to development. One of the most important reasons for a Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land and the Secretary of State’s letter in December also made a “brownfield first” pledge which should be the basis of the way that a District Council such as Warwick responds to unmet housing need in other neighbouring authorities. So, the “brownfield first” pledge should be reflected in any duty to cooperate with other local authorities, ensuring that larger conurbations do look hard at creative brownfield solutions close to where people work. Developers may well prefer to use Greenfield sites as these are easier to development, but that appears to go against the latest Government advice. The letter from the Secretary of State does in itself justify halting the current work on the South Warwickshire Local Plan until the Government’s intentions are clear. The Green Belt around the North of Leamington is highly valued open space. Local residents tell us that it is very valuable to them for both their physical and mental health. It is visually of a very high quality and has a number of easily accessible public right of way footpaths across the fields. These footpaths were heavily used during lockdown, and the gratitude that residents felt to the local farmer for his understanding was evidenced by the thousands of pounds raised for the charity of his choice. The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. It is to be noted that 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 Government is clear that it seeks to protect such land from non-agricultural development indeed the National Planning Policy Framework states, “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 higher quality”. The agricultural land provides rural employment and the mixed arable, grazing and wildlife refuge all helps to maintain the wonderful ambience of the rural village of Old Milverton only a short distance from the Leamington Spa, but with a totally rural feel. Development within the Green Belt to the north of Leamington Spa would substantially reduce the land that separates Kenilworth from Leamington Spa. This is even more the case since the current Local Plan which in reviewing the Green Belt removed land to the south of Kenilworth and north of the A46 from the Green Belt. The joint Green Belt study in 2015 highlighted the contribution to preventing the the merger of Leamington Spa, Kenilworth and Coventry that this part of the Green Belt makes by stopping urban sprawl, protecting the countryside and preserving the special character of these differing but very special historic towns. The Planning Inspector’s 2017 response to the current Warwick District Local Plan 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” (p18, para 91). It also points out that: “Development to 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 significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p34, para 201). The construction of HS2 has made the existing Green Belt even more valuable and the Inspector’s wise comments are indeed more relevant than they were in 2017. There is concern that the assessments of the two proposed development sites are in the 477 page appendix to the Sustainability Appraisal (pages B68 and B74) are not referenced in the main consultation. Both assessments state that the locations would be “unlikely to lead to coalescence of settlements”. However any development would join Old Milverton and Blackdown to Leamington Spa and bring Leamington Spa close to the southern suburbs of Kenilworth. The Green Belt has a major purpose in stemming the loss of open space between the West Midlands, a major urban conurbation, and neighbouring towns and villages, the opposite of what the proposed developments would produce. The officers have done considerable work on the Issues and Options consultation of the South Warwickshire Local Plan, but sadly the process is flawed because all five spatial growth options involve some development in the Green Belt. It is even more unfortunate that all of them refer to the Green Belt to the North of Leamington as an area of ‘significant urban extension’. This all appears to ignore the legitimate function served by the Green Belt, this is contrary to very recent Government announcements, the 2015 green belt review and the detailed 2017 response by the Planning Inspector.

Q-S1 14. At this stage, reliance should be placed upon the Local Nature Recovery Strategy. Q-S2 15. Richborough Estates is aware of the potential changes to the NPPF concerning increasing density of development and protecting the character or areas by not having too greater density of development. 16. Richborough Estates is supportive of intensification of development in the right locations which are generally geographically within the urban areas. However, the consequence of intensification is twofold. First, the nature of the accommodation provided tends to be smaller dwellings, usually flats, rather than providing a cross section of new homes which is easier to achieve on medium/large sites. Secondly, and although design codes are mentioned, the character of the area inevitably changes, if the density of development is higher than the existing urban fabric, especially within suburban areas. 17. In reality, the density of development should be driven by the character of the surrounding area not just an attempt through specific density targets to potentially overdevelop land within urban areas which leads to unattractive developments and housing types of the wrong type. Having said this, there is scope for medium/large sites, especially greenfield sites, to create their own character and be able to accommodate a different density of development from that which prevails in the surrounding area. Q-3.2 18. There is merit in directing growth to previously developed land within the built-up areas for housing purposes but not at the expense of diluting the employment land offer. Having employment opportunities available within urban areas is important to delivering a 20-minute neighbourhood concept. If employment land is lost to housing within the urban areas then all that happens is the future residents have to commute to the new employment allocations on the edges of settlements or, especially for logistics, remote locations adjacent to transport nodes. Q-S5.2 21. NPPF paragraph 72 refers to the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. “Significant” can mean a different scale of growth dependent upon the size of the settlement. However, a balanced approach to the dispersal of growth to range of settlements rather than just directing new development to a new settlement is to be preferred. 22. As has become increasingly evident through the Government’s Garden Communities Programme, the aspiration to deliver new garden communities is laudable but the cost of delivering a scheme is increasingly difficult without significant intervention in the form of financial assistance. Further, a new settlement is often in a more remote location away from existing settlements or seeks to expand a smaller settlement (e.g. Long Marston) but there is the need for investment by the public sector in delivering the services required to support a community (e.g.M40 improvements at Gaydon). As simple points, a school or healthcare building can be built but it requires the people to operate the facility. 23. By reason of the financial and implementation difficulties, which can extend to securing all the necessary land, a new settlement is not a logical or appropriate option for South Warwickshire at this time. Q-S5.3 24. Some growth along the rail corridors provides a sustainable strategy but consideration needs to be given to the scale of any development at particular settlements. For example, although both are suitable to accommodate new homes, the scale of growth at Kenilworth will inevitably be greater than at Hampton Magna because of the level of facilities and services available. However, it is worth noting that Warwick Parkway is an underutilised transport hub and consideration should be given to more growth at Hampton Magna to exploit the locational credentials of this hub. 25. Further, with the exceptions of parts of Warwick, Leamington Spa and Stratford upon Avon, the majority of the railway stations within South Warwickshire are associated with smaller scale villages located in the Green Belt and both the lack of facilities and Green Belt policy (especially as proposed to be amended in the NPPF) will act as a constraint to significant growth at these villages. Hampton Magna is an exception for the reasons given. Q-S8.1 32. The opportunity should be taken as part of this Local Plan to consider the growth needs and capacity of individual smaller settlements to accommodate growth. In this context, the approach is directed towards growth at the Category 1 and 2 Local Service Villages as identified in the Stratford upon Avon Core Strategy. Growth at Category 3 settlements and below should be a matter for Neighbourhood Plans. Q-S9 33. Settlement boundaries will need to be reviewed to accommodate development.

Firstly, I would like to refer to the inevitable population decline by 2050 and that by this time the majority of the ‘Baby Boomer’ generation will be deceased, leaving a much greater-than-average proportion of empty, available homes coinciding with the vast number of homes planned in the SWLP. I feel It is important to consider this when assessing the need for high housing targets anywhere over the next 20-30 years. Specifically regarding Wootton Wawen: Wootton Wawen is one of the most beautiful villages in England, let alone Warwickshire and is admired by visitors and walkers alike. Part of it is a conservation area for its beauty (and holds important public footpaths such as the Monarch’s Way) and historic buildings. Wootton Wawen comprises 350 homes so any significant number of houses built here would fundamentally destroy the inherent character, beauty and infrastructure of the village. To extend a village of this size by more houses would alter the integrity of the village and the benefits it provides to the people who choose to live here. This would also go against one of the 5 overarching principles of the Plan’s vision and objectives: A well-designed and beautiful South Warwickshire In addition, Wootton Wawen is prone to flooding so the majority of the accommodation in the village is limited to certain areas. There is a Doctor’s surgery and amenities with sufficient school places locally in Henley in Arden. The residents own cars, so any perceived benefits in expanding the existing infrastructure are unnecessary. There is no space to build a car park at the train station, and given that the train service is not regular and underused at Wootton (most people use their cars and Wootton is a request stop), to expand this station with Henley train station only a mile or so away would not be feasible. More houses also means more cars and the Henley junction at Warwick Road gets very congested at busy times, this would cause more traffic emissions near the schools. There are also ongoing problems with speeding in the village which would be exacerbated by more cars and also a greater danger to existing and any new residents. Lastly, Wootton Wawen is greenbelt land, which should be preserved according to it’s function. A new government review is making it easier to build on brownfield land and there is a ‘brownfield first’ approach in planning policy which reduces the need to build on greenfield sites. I would like to see this approach applied to the whole of the South Warwickshire Local Plan. I strongly believe that Wootton Wawen and similar sized beautiful villages, are not suitable for any developments greater than a handful of houses built in small pockets where the residents would want them.

Q-S1 14. At this stage, reliance should be placed upon the Local Nature Recovery Strategy. Q-S2 15. Richborough Estates is aware of the potential changes to the NPPF concerning increasing density of development and protecting the character or areas by not having too greater density of development. Q-S5.2 21. NPPF paragraph 72 refers to the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. “Significant” can mean a different scale of growth dependent upon the size of the settlement. However, a balanced approach to the dispersal of growth to range of settlements rather than just directing new development to a new settlement is to be preferred. 22. As has become increasingly evident through the Government’s Garden Communities Programme, the aspiration to deliver new garden communities is laudable but the cost of delivering a scheme is increasingly difficult without significant intervention in the form of financial assistance. Further, a new settlement is often in a more remote location away from existing settlements or seeks to expand a smaller settlement (e.g. Long Marston) but there is the need for investment by the public sector in delivering the services required to support a community (e.g.M40 improvements at Gaydon). As simple points, a school or healthcare building can be built but it requires the people to operate the facility. 23. By reason of the financial and implementation difficulties, which can extend to securing all the necessary land, a new settlement is not a logical or appropriate option for South Warwickshire at this time. Q-S5.3 24. Some growth along the rail corridors provides a sustainable strategy but consideration needs to be given to the scale of any development at particular settlements. For example, although both are suitable to accommodate new homes, the scale of growth at Kenilworth will inevitably be greater than at other settlements because of the level of facilities and services available. 25. Further, with the exceptions of parts of Warwick, Leamington Spa and Stratford upon Avon, the majority of the railway stations within South Warwickshire are associated with smaller scale villages located in the Green Belt and both the lack of facilities and Green Belt policy (especially as proposed to be amended in the NPPF) will act as a constraint to significant growth at these villages. 16. Richborough Estates is supportive of intensification of development in the right locations which are generally geographically within the urban areas. However, the consequence of intensification is twofold. First, the nature of the accommodation provided tends to be smaller dwellings, usually flats, rather than providing a cross section of new homes which is easier to achieve on medium/large sites. Secondly, and although design codes are mentioned, the character of the area inevitably changes, if the density of development is higher than the existing urban fabric, especially within suburban areas. 17. In reality, the density of development should be driven by the character of the surrounding area not just an attempt through specific density targets to potentially overdevelop land within urban areas which leads to unattractive developments and housing types of the wrong type. Having said this, there is scope for medium/large sites, especially greenfield sites, to create their own character and be able to accommodate a different density of development from that which prevails in the surrounding area. Q-3.2 18. There is merit in directing growth to previously developed land within the built-up areas for housing purposes but not at the expense of diluting the employment land offer. Having employment opportunities available within urban areas is important to delivering a 20-minute neighbourhood concept. If employment land is lost to housing within the urban areas then all that happens is the future residents have to commute to the new employment allocations on the edges of settlements or, especially for logistics, remote locations adjacent to transport nodes. Q-S8.1 33. The opportunity should be taken as part of this Local Plan to consider the growth needs and capacity of individual smaller settlements to accommodate growth. In this context, the approach is directed towards growth at the Category 1 and 2 Local Service Villages as identified in the Stratford upon Avon Core Strategy. Growth at Category 3 settlements and below should be a matter for Neighbourhood Plans. Q-S9 34. Settlement boundaries will need to be reviewed to accommodate development.

Q-S1: Please select the option which is most appropriate for South Warwickshire Option S1a: Coventry City Council supports continued partnership working across the Sub-Region and supports the delivery of key evidence documents which inform Local Plan policy. It is the councils view that strategic green and blue corridors be identified in advance of the LNRS, using information from existing sources and the forthcoming Sub-Regional Green Infrastructure Strategy.

Issue S1: Green and Blue infrastructure. Q S1a&b. Overall the Chamber supports the overall “hierarchical “ approach to settlement planning outlined in the emerging strategy. However, as the Chamber has noted above , there is a lack of real detail supporting much of the emerging strategy and the Chamber will await further evidence and background information before making specific comment on the distribution strategy. The Chamber particularly welcomes the recognition in the draft proposals relating to a much clearer appreciation and proactive understanding that improving both “green “ and “blue “ infrastructure environments must be a key and proactive part of economic and social planning rather than simply an “afterthought”. The Chamber recognizes that this specific distinctive treatment of infrastructure has potential to contribute proactively to the planning of industry; and employment and can improve the quality of life in South Warwickshire. Issue S2; Intensification. Q-S2 a,b,c. The Chamber cautions against the use of this blanket approach. Over the past 10 years against a background of greater differentials in prevailing land values much employment land and premises have been lost principally to new housing. Indeed this has been reinforced by national policies .At the same time many local planning authorities have failed to protect areas of employment concentration particularly in urban areas. The effect of this has been a loss of cheaper often lower quality business space. This type of space forms a vital component of a functioning employment land market. The result is that there are now significant “gaps’ in the provision of some types of employment and business space. Perhaps the best current example is storage space where much of the stock of such spaces and premises in urban areas has been lost. These losses have often generated unsustainable alternative locations in rural locations. The general concern is that by a process of intensification losses of important elements of cities, towns and smaller communities are lost. On a related point, the Chamber is concerned with an overreliance on the new Use Classes Order to allocate and regulate commercial space. See the Chambers comments below which relate to the same general point. Issue S3: Using Brownfield land. Q-S3.1, 3.2a-c. It is national policy to prioritise the development of brown field land. However it must be acknowledged that the policy as applied in recent times is partly responsible for the loss of significant areas of valuable small scale industry and business premises and a loss overall of employment land. This is well documented. In particular the application of the policy has resulted in the loss of significant land and premises that provide accommodation at the lower end of the market and which has eroded the supply of cheaper more affordable premises. In some local authorities this is recognized and is balance by policies that seek to protect local businesses and require that if brownfield land that supports employment use is threatened then a detailed assessment and balancing of priorities is under taken .The Chamber fully supports such a policy approach to “testing “these development pressures .The adopted Rugby Borough Local Plan contains a comprehensive policy (ED1: RBC adopted local plan) that seeks to protect its stock of employment land and establishes a series of “tests’ in the event that changes /loss of employment land is promoted .The Chamber fully supports this type of comprehensive policy that would go some way to protecting employment assets. Issue S4: Growth of existing settlements Q-S4,1-2 The Chamber agrees that the existing framework and hierarchy of settlements provides a good basis for future land use allocations .The Chamber would like to see a range of new employment land provided across the existing built framework. There appear to be good opportunities across all settlements of varying size to facilitate and allocate the provision of new employment allocations of an appropriate scale. In this way it will encourage a better relationship of homes and job opportunities and underpin sustainable development .As recognized by the SDC draft policy framework in relation to Employment Enabling Sites (ref SAP 8- draft Site Allocations Plan 2021)there are opportunities to provide a supply of small scale low cost affordable units in smaller communities and settlements. Issue S5, The potential for New Settlements. Q-S5.1,2,3,4 As recognized in the text of the document, with the plan framework running to 2050 it seems likely that the provision of new settlements will be required to sit alongside growth provision achieved by extending settlements. Therefore the Chamber supports the initiative. The difficulty of establishing a genuinely sustainable new community, as distinct from a large housing scheme, represents a major challenge. Fundamentally it requires significant resource and commitment from both public and private sectors. On a point of relative detail it is suggested that more in depth work is carried out to look at development thresholds and viability in new communities. Put another way how do we create genuinely sustainable new development? There is a considerable pool of experience and knowledge to draw on. The New Towns programme and the Garden City developments exemplify this. They provide evidence that in order to support good levels of facilities and services significant scale and concentrations of development are required. Otherwise without sufficient “critical mass” small scale new settlements run a danger of evolving into large isolated estates with minimum facilities and become “car dependent” .The thresholds quoted (Ref; Table3, p48) seem low but the consultation is not clear about what actual scale of new settlement is being tested. As an example it seems highly unlikely that the rail industry, and particularly the Train Operating Companies, would be prepared to open a new railway station on the basis of the 6000 dwellings quoted (ref; Table 3 p48.) The Chamber of Commerce would support a bold long term planning approach whereby a policy framework that includes new settlements would set out ambitious and long-term aspirations for relatively large-scale new communities. This would include the provision of significant new jobs, community facilities, environmental and social infrastructure alongside significant dwelling provision. This will increase the sustainability of the overall strategy and deliver a wider range of jobs. Issue S6. Green Belt boundaries. The Chamber fully supports and welcomes the stated intention to review current Green Belt boundaries as referenced at Issue S6 (page 57) in the draft document. Given the duration of the strategy and the wider sub regional growth context it appears unlikely that the levels of growth indicated in the HEDNA papers can be accommodated without changes to green belt across this plan and indeed across the sub region .The Chamber would support this review for the joint plan area being done in conjunction with this review and that it should not be dependent on individual reviews of the whole sub region .This is because the timing and programmes of other areas largely remains unclear and a wider GB review could seriously delay this plan .There already exists a reasonably up to date technical evidence base (reference here to Land use Consultants Study 2016).This work could form a good baseline for further work on altering the relevant green belt boundaries across this plan area. It would also save time and resources duplicating previous relatively recent work. Issue 7. Options for Growth. Q-S7 2 Options 1-5. At this point in the plan making process the Chamber feels that there is not enough evidence base or complete information to support any single growth option. Generally, the Chamber supports the Options that feature a strong economic emphasis and content .The Chamber notes that there is considerable overlap between many of the options. Options 3&4 align most closely with the Chambers aspiration to see the plan underpinned by strong economic principles but other Options, say 1(Rail Corridors)&2(Sustainable Travel) would be easily adapted to reflect the Chambers position. The adoption of a dispersed development strategy as set out in Option 5,appears unlikely to be the basis of a long term sustainable development framework that can underpin a growing economy . As noted above caution needs to be applied to embracing rail-based options that depend solely on rail .The whole rail system in the UK remains in a state of flux and national reforms and major investment are required to create capacity to address current operating difficulties. Rail travel is underpinned by complex public and privately operated systems that need to be fully understood in order to develop new and practical rail based growth. We see no evidence that the rail based options set out here have been “stress tested ‘ in terms of feasibility and deliverability. Issue S8. Small Scale Development outside the spatial growth option. Q-8.1&2 It follows from the Chambers comments above that it would strongly support small-scale development outside of the chosen spatial growth option. From an economic point of view it essential that the development strategy facilitates a wide range of growth and maximized opportunity for new job creation in a variety of locations including rural areas and small communities. It whole-heartedly supports the view that small-scale development can play a role in maintaining the vitality and viability of small settlements. This general approach should encompass encouraging the provision of new employment allocations in smaller communities usually rural areas. We would not advocate so called “ threshold approach “, which might unduly constrain and discourage entrepreneurial opportunity. We do not believe that a firm “threshold “ approach gives sufficient flexibility to meet all circumstances. Here the thrust seems to be focused on housing and not commercial development.

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

You have asked for comments to be submitted by the 6th March 2023 on SWLP our comments below are in relation to possible developments in or near Wilmcote. 1. Wilmcote is within the Green Belt the purpose of which is to protect from over development. Any development other than "in fill " would require changes to the designated green belt area and would set an unfavourable president . 2. SWLP identifies Wilmcote as having a station which may contribute towards sustainable travel however there are no car parking facilities whatsoever, and no disabled facilities on the station which in our opinion makes it unsuitable. 3. The village primary school is very small and would not be capable of accommodating a significant number of additional children. 4. Significant additional housing would undoubtedly create greater vehicle traffic, and the village, in parts suffers from a lack of pedestrian foot paths thus additional development could well be hazardous to residents. 5. The site offered on the south side of Featherbed Lane is likely to cause traffic bottlenecks at the junction with the A3400 We hope you will take these comments into account when finalising the plans.

I write to register my comments on the current South Warwickshire Local Plan, as detailed above. I wish to object to the changes to Green Belt Boundaries around Leamington Spa, where I was born and have grown up. [Redacted Text] I am concerned that the Green Belt is not given sufficient weight in the Issues and Options Consultation on the South Warwickshire Local Plan. In my opinion, the Green Belt around the North of Leamington fulfils all of the five stated purposes of Green Belt land. The Government has recently made it clear in a letter from the Secretary of State for Levelling Up, Housing and Communities, that local planning authorities such as Warwick District Council are not expected to review the Green Belt to deliver housing. Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is, to quote the letter from Michael Gove MP “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The Green Belt around North Leamington is recognised as a genuine constraint to development. One of the most important reasons for a Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land and the Secretary of State’s letter in December also made a “brownfield first” pledge which should be the basis of the way that a District Council such as Warwick responds to unmet housing need in other neighbouring authorities. So, the “brownfield first” pledge should be reflected in any duty to cooperate with other local authorities, ensuring that larger conurbations do look hard at creative brownfield solutions close to where people work. Developers may well prefer to use greenfield sites as these are easier to develop, but that appears to go against the latest Government advice. I am also concerned about the statistics in Chapter 4, issue S6 that state that 54% of respondents to the first consultation, Scoping and Call for Sites, supported “exploration for growth opportunities” in the Green Belt. The planning team appear to be using this as one of the justifications for reviewing Green Belt boundaries. However, I believe some 35% of respondents to that consultation were developers and 10% were businesses or landowners, suggesting that only a small proportion of other respondents were in favour. The heavy weighting towards groups with vested interests should be treated with caution and certainly not used as justification. The letter from the Secretary of State does in itself justify halting the current work on the South Warwickshire Local Plan until the updated NPPF is finalised. This would enable the South Warwickshire Local Plan to be realigned with the Government’s clear intention for planning authorities to have more power to resist identifying Green Belt land for development if the only solution for meeting assessed housing need would be to build on Green Belt land. The Green Belt around the North of Leamington is a highly valued open space. As a local resident I have, over many years and continuing to this day, found these spaces very valuable both in terms of my physical and mental health. I would also comment that whenever I see or use these spaces, it is rare not to find other members of the public using the space for walking, running, dog-walking, bird-watching etc. It is visually of a very high quality and has a number of easily accessible public footpaths across the fields. When walking these footpaths I have enjoyed seeing a wide variety of local wildlife, including deer, badgers, buzzards, red kites and woodpeckers to name but a few. These footpaths were heavily used during lockdown, and the gratitude that residents felt to the local farmer for his understanding was evidenced by the thousands of pounds raised for the charity of his choice. The farmland is high-quality agricultural land and makes an important contribution to sustainability and security of food supply. I believe that this is a critical issue for this country going forward and a major reason for preserving green belt agricultural land. It is also to be noted that 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 Government is clear that it seeks to protect such land from non-agricultural development, and indeed the National Planning Policy Framework states, “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 higher quality”. The agricultural land provides rural employment and the mixed arable, grazing and wildlife refuge all helps to maintain the wonderful ambience of the rural village of Old Milverton only a short distance from Leamington Spa, but with a totally rural feel. Development within the Green Belt to the north of Leamington Spa would substantially reduce the land that separates the distinctly different towns of Kenilworth and Leamington Spa. This is even more the case since the current Local Plan, which in reviewing the Green Belt removed land to the south of Kenilworth and north of the A46 from the Green Belt. The joint Green Belt study in 2015 highlighted the contribution to preventing the merger of Leamington Spa, Kenilworth and Coventry that this part of the Green Belt makes by stopping urban sprawl, protecting the countryside and preserving the special character of these differing but very special historic towns. The routeing of HS2 in this area has also had a significant negative impact on Green Belt space in this area. The Planning Inspector’s 2017 response to the current Warwick District Local Plan 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” (p18, para 91). It also points out that: “Development to 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 significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p34, para 201). The construction of HS2 has made the existing Green Belt even more valuable and the Inspector’s wise comments are indeed more relevant now, than they were in 2017. There is concern that the assessments of the two proposed development sites are in the 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both assessments state that the locations would be “unlikely to lead to coalescence of settlements”. However, any development would join Old Milverton and Blackdown to Leamington Spa and bring Leamington Spa close to the southern suburbs of Kenilworth. The Green Belt has a major purpose in stemming the loss of open space between the West Midlands, a major urban conurbation, and neighbouring towns and villages. The proposed developments would significantly reduce that green corridor, and have a detrimental impact. The officers have done considerable work on the Issues and Options consultation of the South Warwickshire Local Plan, but sadly the process is flawed because all five spatial growth options involve some development in the Green Belt. It is even more unfortunate that all of them refer to the Green Belt to the North of Leamington as an area of ‘significant urban extension’. This all appears to ignore the legitimate function served by the Green Belt, and is contrary to very recent Government announcements, the 2015 green belt review and the detailed 2017 response by the Planning Inspector.

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

Issue S6: A review of Green Belt boundaries Green Belt boundaries should remain as they are or restored to previous positions where it is now obvious that land needs have been exaggerated.- in particular the safeguarded land at Westwood Heath, and the land for a further 1500 homes at Kings Hill. Housing should be concentrated within existing boundaries. A greater density of housing will reduce carbon emissions. Research shows that suburban homes produce 2 to 4 times as much CO2/person as city centre dwellings. All of the land taken out of green belt for unmet Coventry need should now be returned to green belt, as the alleged population bonanza never happened – specifically land between Coventry, Kenilworth, and Warwick University should be returned to green belt.

• Issue S6: A review of Green Belt boundaries Green Belt boundaries should remain as they are. Housing should be concentrated within existing boundaries. A greater density of housing will reduce carbon emissions. Research shows that suburban homes produce 2 to 4 times as much CO2/person as city centre dwellings. All of the land taken out of green belt for unmet Coventry need should now be returned to green belt, as the alleged population bonanza never happened – specifically land between Coventry, Kenilworth, and Warwick University should be returned to green belt. I endorse the CPRE document attached.

Q-S5.2: New Settlements will play an important role in the overall strategy for the SWLP. New Settlements are an effective and sustainable way of meeting the challenges of delivering significant housing growth. Creating a new community can deliver significant benefits in relation to infrastructure, open space and homes for the residents of south Warwickshire. Section 3 of these representations (and the Vision Document enclosed at Appendix 1) sets out the unique opportunity of Hatton New Community, which will be able to provide benefits to future residents from day one. Q-S5.3: Hill Residential support the approach of considering Rail Corridors as a preferred approach to identifying potential new settlement locations. Building on the existing infrastructure is a logical approach and ensures that there is a sustainable mode of transport for residents from day one. As set out in our responses relating to the SA and Emissions Estimations, it is important to ensure that when considering Rail Corridors as a growth option, any assessment should be mindful that any development would be a large scale new settlement. This approach will ensure that all factors are assessed ‘in the round’. Q-S10: Hill Residential support the development distribution strategy for South Warwickshire. The SWLP is looking to develop a strategy to 2050, this would result in a significant housing requirement for the south Warwickshire authorities of over 48,000 homes (Based on trend-based housing projections set out at Table 15.1 of the Coventry and Warwickshire HEDNA (November 2022) and a plan period of 2021 to 2050). In order to deliver this scale of new development, it is important that the SWLP has a dynamic and forward looking distribution strategy. This strategy should include the allocation of at least one new settlement, in a sustainable location such as Hatton.