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

Issue S6: A review of Green Belt boundaries As stated above, there should be a moratorium on green field or green belt building for 5 to 10 years, to see how house building needs evolve, and to include real information about population change. In that time Green Belt boundaries should not be changed.

HS2 is not a railway corridor that serves South Warwickshire; land in this corridor should not be seen area of potential spatial growth.

Issues for the Parish of Bishop’s Tachbrook The fact that the village of Bishop’s Tachbrook and the new estates around Harbury Lane are divorced from one another throughout the consultation document make it difficult to envisage the overall impact on the parish that we as councillors are responsible for. It also doesn’t really highlight the huge changes that have taken place across BT parish. Whilst we acknowledge that new housing has been positive for the parish, and we welcome new residents. However, the quadrupling of the population of the parish has threatened the rural identity of the village. Some of the sites offered in the ‘call for sites’ would dramatically cut the space between the village and South Leamington increasing the feelings, already prevalent amongst villagers, that the village is loosing its rural identity. When allocating sites in the next stage of the plan this needs to be taken into account. Referring to the above, it is great concern that none of the maps and diagrams we have looked at, contain the Country Park or Oakley Grove school. To not show them could lead to bad decision making. As an example of what this could lead to, we refer you to the Arup urban capacity map for the area. This shows the old Seven Trent waterworks site as not suitable for development when, under the WLP to 2029, part is already allocated for housing (the planning application is expected soon) and part is in the Country Park. In the consultation document the village settlement of Bishop’s Tachbrook is referred to as a small town/large village. In other supporting documents it is referred to as a small settlement. We certainly do not see ourselves as a small town and the implication that this means we could have 50-500 extra houses on top of the 200 that have been built under the WLP to 2029, fills us with trepidation. Even the lower figure of 50 houses would mean another village changing development. We think we ought to be reclassified to village status i.e. a small settlement.

Option S2-C: Intensification 7. 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. 8. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? 33. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Rosconn Strategic Land agree that a threshold approach would be appropriate for any settlement listed within Option 5 not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66 Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 34. Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the size and availability of suitable land identified. Stratford-on-Avon District Council has already identified suitable and sustainable sites for allocation as part of its emerging SAP. Therefore, the threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.

Option S2-C: Intensification 11. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Rosconn Strategic Land consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 12. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided. Q-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? 32. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Rosconn Strategic Land agree that a threshold approach would be appropriate for any settlement listed within Option 5 not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 33. Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the size and availability of suitable land identified. The threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.

Option S2-C: Intensification 5. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Rosconn Strategic Land consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 6. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? 30. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Rosconn Strategic Land agree that a threshold approach would be appropriate for any settlement listed within Option 5 not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 31. Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the size and availability of suitable land identified. The threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.

Option S2-C: Intensification 13. 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. 14. 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? 29. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Rosconn Strategic Land agree that a threshold approach would be appropriate for any settlement listed within the growth options that is 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? 30. 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, and the facilities available.

Option S2-C: Intensification 15. 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. 16. 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? 41. 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? 42. 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.

Option S2-C: Intensification 9. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Countryside Properties consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 10. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided.

2 THE SITE AND PROPOSALS 2.1 It is acknowledged that the Part 1 SWLP is unlikely to allocate sites of the scale of Kings Meadow Phase 2, however for information set out below is a brief summary of the emerging proposals for the site, with further detail set out in Appendix A. The site has previously been identified as a reserve site in the emerging Site Allocations Plan being prepared by Stratford-on-Avon District Council. 2.2 The site is adjacent to the northern settlement edge of Bidford-on-Avon, less than 1 km from the village centre and adjoins Miller Homes Phase 1 site which is currently being built out for 200 new homes. Bidford-on-Avon is situated approximately 10 km to the west-south-west of Stratford-upon- Avon, 6 km to the south of Alcester and 10 km to the north east of Evesham. Bidford-on-Avon is located immediately north of a meander on the River Avon and to the East of the River Arrow Valley. 2.3 The site consists of a single field, currently in agricultural use, that is adjacent to an unnamed track to the northern boundary of the site, that links to Victoria Road / Bidford Road to the west of the Site. A watercourse, Small Brook, runs adjacent to the track and is a tributary of the River Avon. An established hedgerow separates the track from the Small Brook. The southern boundary of the site adjoins the Miller Homes Phase 1 site currently under construction. The western boundary adjoins the edge of a recently completed residential development at Jacksons Meadow. The eastern boundary of the site adjoins the garden of a residential property. The site is shown below and its relationship to the development at Jacksons Meadow and its relationship with the Miller Homes Phase 1 development to the south. Figure 2.1 - The site and relationship to phase 1 Miller Homes development to south [see submission document] 2.4 Development has built up along the B439 Stratford Road that runs east-west, just north of the town centre. Development is also situated along two roads running north from there: Victoria Road to the west and Waterloo Road to the east. The Site sits between these two roads. Existing residential development at Bidford-on- Avon is situated on land between 25m AOD and 52m AOD. 2.5 As set out in the accompanying vision document (Appendix A) the vision for the Site is to deliver an attractive development offering a choice of high quality affordable and market new homes to meet local needs and being fully integrated with, and complementary to, the village of Bidford-on-Avon. Miller Homes has developed an illustrative concept masterplan which reflects the opportunities and constraints that have been identified through the evidence base for the application on the land to the south, and subsequent further technical work on landscape and highways. It is intended that the illustrative masterplan shown below is used as a starting point to inform discussions on the Site and that the plans will evolve further following consultation with the local community, the Council and any other key stakeholders. Figure 2.2 - Illustrative Masterplan [see submission document] 2.6 Vehicular access would be provided towards the south eastern corner of the Site, linking directly into the wider Miller Homes site to the south, ultimately linking the site to Waterloo Road to the east. The illustrative masterplan shows how access to the land to the east of the Site, which is outside of the control of Miller Homes, could be provided through the Site linking it to the larger Miller Homes site to the south. 2.7 The illustrative concept masterplan demonstrates that a significant amount of green infrastructure could be provided within the Site as part of the proposed development. In particular areas of green, open space, are shown within the illustrative masterplan to the eastern and southern boundaries of the Site that would enable the development to seamlessly integrate with the approved development to the south. The scheme has taken account of the work undertaken as part of the Landscape and Visual Assessment and substantial hedgerow and tree planting would be provided across the Site, within both public areas and private gardens, to ensure a high-quality form of development that reflects its location. Whilst further details would be provided at the application stage, the proposals allow for a strong landscape barrier to the north of the site to ensure that a strong, defensible barrier, can be created. 2.8 The illustrative concept masterplan demonstrates that the site can accommodate up to 90 dwellings at a density of approximately 30 dwellings per hectare. This ensures that the development would reflect the general character and density of development within the surrounding area and that it would protect the residential amenity of the occupiers of existing and proposed residents alike.

Issue S2: Intensification Q-S2: Please select all options which are appropriate for South Warwickshire 4.1 Under this issue, the IO document does not pose any specific questions, but instead identifies three options for developing a policy to support the intensification of existing areas. 4.2 National policy provides advice on achieving appropriate densities as part of the overall objective to make efficient use of land1 or for optimising the density of development in city and town centres and other locations that are well served by public transport2. This includes taking into account the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change3, as well maintaining the viability of development4. It is also advised that it may be appropriate to set out a range of densities that reflect the accessibility and potential of different areas, rather than one broad density range5. 4.3 In this context, it is clearly the case that some localities more central to existing built-up areas may be more predisposed to accommodate more intensive development than other locations. Nonetheless, delivering development at increasingly higher densities will inevitably lead to potential impacts on the prevailing character and setting of existing settlements. Therefore, whilst increasing densities could increase the supply of housing, this should not be seen as the only option. In this context, there is clearly a role for development that is brought forward on the edge of existing settlements that can be designed in order to integrate with existing areas but also help to create distinctive places in their own right. 4.4 Consequently, RPS recommends a design-led approach to establishing strategies on density. Density is a function of good design and there is no reason to take an alternative approach when devising local policy through the SWLP. On this basis, any policy approach should be informed by an assessment of the character of different areas because character is not uniform across the plan area. This is in preference to any blanket or an ‘in-principle’ approach. Similarly, there should not be any overarching priority to intensify or densify existing urban areas because other evidence, principally the Urban Capacity Study, shows that the development needs of the SW area will not be met through urban-focused / brownfield growth alone. This is discussed in the response to Issue S3 below. 4.5 RPS therefore would favour Option S2a, which would direct any policy response to localities where intensification is considered to be appropriate, but which recognises that less intensive or development at relatively lower (but compatible or complimentary) densities are also acceptable if designed sensitively. 1 NPPF2021, paragraph 124 2 Paragraph 108 3 Paragraph 124d 4 Paragraph 124b 5 Paragraph 125b Issue S4: Growth of existing settlements Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 4.16 Yes. 4.17 There are a number of national and local factors that clearly demonstrate the appropriateness of a strategy which directs future growth to existing settlements within South Warwickshire. 4.18 Paragraph 69 of the NPPF recognises the important contribution that small and medium-sized sites can make to meeting the housing requirements of an area, which can be built out relatively quickly. This provides clear support for directing future growth to appropriately-sized sites on the edge of existing settlements and which can deliver sustainable development. And paragraph 85 also provides support for sites and locations that can meet the community (and business) needs of rural areas adjacent to or beyond existing settlements, and where sites are physically well-related to settlements such opportunities should be encouraged where suitable. Consequently, national policy clearly provides sufficient support and policy direction for focusing growth at or around existing settlements. 4.19 At the local level, RPS notes Table 2 of the IO document which lists a number of existing settlements identified in adopted plans across South Warwickshire. These include Bidford-on-Avon. The settlement has been subjected to separate connectivity, accessibility and density analysis, which RPS responds to question Q-S4.2 under section 6 of this submission. Sustainability Appraisal (SA) has also been carried out on the broad locations within which the settlement is situated, and a response to the SA is provided in section 5 of this submission to question Q-I1. 4.20 The IO document hints at what the emerging development strategy might comprise based on commentary set out in the second paragraph under this issue (on page 43). This states that the SWLP will seek to: “…maximise the capacity of its existing urban areas in order to meet our development needs to 2050 (see Issue S2). However, in deciding upon the best distribution strategy for new development within South Warwickshire it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements, potentially alongside and in combination with other options such as new settlements (see Issue S5).” 4.21 In light of the findings of the Urban Capacity Study as discussed under Issue S3 of this submission, even when the capacity within existing urban areas on previously-developed land has been assessed it is clear that this will not be sufficient to meet the needs of the South Warwickshire District in the long term. It is therefore inevitable that development around the edges of existing settlements will be required, given these provide opportunities to deliver sustainable development on largely unconstrained land which can be built out quickly, or where larger sites are concerned these can deliver a steady quantum of development over a period of time in order to help maintain delivery against the targets in the SWLP. 4.22 Based on the foregoing analysis, RPS contends that focusing growth as part of the emerging development strategy on existing settlements, including Bidford-on-Avon, aligns with national policy and offers clear potential to meet the development needs of the area, in light of the acknowledged constraints on land supply within settlements. The strategy should therefore incorporate locations for growth around and on the edge of existing settlements where local services and facilities are already available in close proximity to communities in order to achieve wider sustainable development objectives. Issue S5: The potential for new settlement(s) 4.23 The IO document now identifies a number of potential locations for new settlements across South Warwickshire. These have been derived from a two-part process; part 1 seeks to identify ‘areas of search’ based on existing or potential access to rail services outside existing urban areas. Based on the approach, seven areas (A-G) have been identified, illustrated on Figure 12 of the document. These comprise broad areas that do not specify sites or specific locations; part 2 applies a ‘very high-level assessment’ of the areas of search, from which seven potential new settlement locations have been identified. A summary of the assessment of each location is shown in Table 6 of the IO document. Each of these seven locations has also been subjected to Sustainability Appraisal (see RPS responses under Issue I1) and Climate Change Emissions Estimation modelling. 4.24 Whilst some assessment work has been undertaken to date, the IO document acknowledges that further detailed work is required before any preferences for any particular new settlement location can be made, or whether a new settlement is suitable, viable and deliverable in principle. RPS broadly agrees with this point. Q-S5.2: Do you think new settlements should be part of the overall strategy? 4.30 RPS wishes to reiterate its position that it does not object to new settlements forming part of the development strategy in principle. Nonetheless, RPS suggests that caution should be applied in considering new settlements as part of a broader strategy for distributing growth in South Warwickshire. This is because unforeseen issues can occur that can delay progress on new settlement / strategic allocations, for example in Stratford-upon-Avon. In this case, the Core Strategy allocated two new settlements at Gaydon/Lighthorne Heath (2,300 homes) and Long Marston (2,100 homes), 30% of the adopted housing requirement of 14,600 dwellings. However, since 2011 (the base date of the current plan) these two new settlements have only delivered 343 dwellings, just 3.4% of the total housing delivered in the district up to April 2022 7. 4.31 The distribution strategy should therefore also ensure that the needs of local communities can be met through smaller development directed and brought forward at established sustainable settlements that can be delivered relatively quickly, and thus a greater mix of different sized sites should be encouraged to deliver a significant proportion of the required growth in the SW area over the plan period. 7 Stratford-upon-Avon Authority Monitoring Report 2021-22, Table 13 Issue S6: A review of Green Belt boundaries 4.32 RPS notes that the IO document does not include any specific question regarding potential for changes to the Green Belt in South Warwickshire. Nevertheless, national policy8 makes provision for alterations to existing Green Belt boundaries through the updating of plans where the need for changes to Green Belt boundaries is established in the strategic policies. This is normally done through a Green Belt review to inform the development of the spatial strategy and identification of site allocations. 4.33 In this respect, the IO document makes clear that to achieve a growth strategy that addresses the vision and strategic objectives for the Plan, a Green Belt study to review the existing Green Belt boundaries would inform and help to refine the growth options that are set out within the issues and options consultation to enable a preferred approach for South Warwickshire to be established. 4.34 Nevertheless, regardless of whether any Green Belt is released is taken forward, there are opportunities outside the Green Belt where growth can be directed, this includes at Bidford-on-Avon, which is identified as one of the eight ‘Main Rural Centres’ in the adopted Stratford-on-Avon Core Strategy. Bidford-on-Avon therefore can make a valuable contribution towards meeting the housing land supply requirements of South Warwickshire. 8 NPPF 2021 paragraph 140 Issue S9: Settlement Boundaries and infill development 4.60 Under this issue, the IO document indicates that there may be a need to alter existing settlement boundaries to take account of a new growth strategy up to 2050. National policy provides limited assistance to local planning authorities or stakeholders in how to deal with setting or amending settlement boundaries. 4.61 The IO document presents two options. Option S9a would save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Option S9b would review, within this Part 1 Plan, which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 4.62 The IO document makes clear that this plan review relates to part 1 strategic policies only, including strategic allocations and / or new settlement locations, and not non-strategic policies and allocations. On this basis, RPS would favour Option S9a – settlement boundaries should be reviewed at the Part 2 review stage. Given this option refers to the ‘emerging SAP’ RPS assumes that the SAP is still likely to be progressed and adopted including alterations to some settlement boundaries, prior to an immediate review of those boundaries in short order in the Part 2 SWLP. This is logical as the Part 2 SWLP will need to ensure the settlement boundaries at for example Bidford-on-Avon is suitably robust to allow growth to be accommodated up to 2050, as opposed to the SAP which only addresses development needs up to 2031 (and only for Stratford-upon-Avon district). 4.63 RPS have previously submitted responses on behalf of Miller Homes to various consultations on the emerging SAP in relation to their interest in the site, most recently in July 2022 in response to the Revised Preferred Options Consultation. Whilst it is noted that the IO consultation is not considering boundaries in detail RPS maintain the position set out in those representations that the entirety of the site has development potential. 4.64 Furthermore, in order to provide sufficient clarity and to reduce the risk of ambiguity in the Part 1 version, the next iteration of the SWLP (the preferred option draft plan) should make clear which settlement boundaries will need to be reviewed in light of the quantum of growth to be directed to each respective settlement (to deliver the spatial development strategy) and the capacity of those settlements to suitably accommodate that growth within the existing boundaries. Issue S10: Any other development strategy issues Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire: 4.65 The preamble states that Chapter 4 of the IO document 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. 4.66 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 document 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. 4.67 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 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). 4.68 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.

South Warwickshire Local Plan: Issues and Options consultation Worcestershire County Council (WCC) welcomes the opportunity to comment on the above consultation and looks forward to ongoing engagement between our authorities throughout the development of the South Warwickshire Local Plan, be it through the Duty to Co-operate or any replacement mechanism. WCC will be particularly interested in the potential infrastructure implications of growth options, including new settlements and expansions of existing settlements. Set out below are some specific comments relating to minerals, waste, transport and education.

The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives. The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

QS1 select the option which is most appropriate for South Warwickshire Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced South Warwickshire Councils need a clear policy to protect important environmental assets, designated and non designated sites including potential local wildlife sites. As well as a policy to enhance and restore wildlife sites. Without watering down the policy with wording such as ‘where appropriate’ and in line with the priorities of the Biodiversity Action Plan. The Councils need to plan in line with the legal requirements set out in the National Planning Policy Framework (NPPF), 25 year Environment Plan, the Governments commitment to 30% land in nature recovery by 2030, COP 27 and COP 15 and the Councils declared climate change emergencies. National Planning Policy Framework Paragraph 20d) requires ‘conservation and enhancement of the natural...environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation’ Paragraph 175. Requires Councils ‘take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries’. Q S3.2 Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Brownfield site should be given the upmost priority and areas should only be proven to be an unsustainable location if regeneration projects of the area to make it a sustainable option is not viable.

The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives. The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives. The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

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

Issue S1: Green & Blue Corridors As shown on the Vision Document (Appendix 2) and Concept Masterplan for Land South of Allimore Lane, Alcester, it is proposed to retain and enhance the route of Spittle Brook through the Site with a green and blue infrastructure corridor. It is proposed to create two large wet grassland areas along the Spittle Brook Local Wildlife Site, accommodating wetland scrapes and wildlife ponds to provide net gains in biodiversity and to provide multiple ecological benefits. SuDS will also form an integral part of the development’s green infrastructure, providing ecological benefits and habitat creation, as well as performing their principal function of controlling and managing the flow of surface water run-off during periods of heavy and persistent rainfall. The proposals will deliver a number of landscape benefits, including new Public Open Space, play facilities, recreational routes and a community orchard. New planting will include parkland and avenue tree planting as well as native tree belts. Therefore, the proposals for Land South of Allimore Lane, Alcester demonstrate that green and blue infrastructure can be incorporated into development in many forms. It would be advantageous for additional evidence from the emerging Sub-Regional Green Infrastructure Strategy to be made available as soon as possible in order to inform the proposals for the Site. Therefore, Option S1a would be preferable, considering the production of a Local Nature Recovery Strategy will come after the SWLP Spatial Growth Strategy has been determined.

The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives. The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

Gaydon Area Cherwell District Council would like to express an interest in the direction of ‘Issue S5: The Potential for New Settlements’, which considers the potential new settlement at land north east of Knightcote (F3) and ‘Issue E7: Core Opportunity Area and Major Investment Sites’ relating to the site in the Gaydon Area/M40 Junction 12. Given the proximity of Banbury to these areas, there is potential for growth in the Gaydon area to place pressure on local services and transport infrastructure within Cherwell District. There may also be implications for any future growth in the Gaydon area in terms of the capacity of the M40, particularly between Banbury (junction 11) and Gaydon (junction 12). Any adverse impacts from proposals should be considered carefully and mitigated as far as possible. Cherwell District will continue to engage with Stratford-on-Avon and Warwick Councils and the relevant highway authorities on these matters. Other Issues Cherwell District Council also notes the following Issues which are pertinent to consider as cross boundary matters which may have an impact on Cherwell District: • Issue 14: Infrastructure Safeguarding • Issue S1: Green and Blue Corridors • Issue S7: Refined Spatial Growth Options • Issue C11: Water Management • Issue C12: Flood Risk • Issue W1: Pollution • Issue T2: Sustainable Transport Accessibility Across South Warwickshire • Issue T3: Road Travel, Employment, and Freight Issue B4: Protecting the Cotswold Area of Outstanding Natural Beauty (AONB) and Its Surrounding Areas • Issue B9: Protecting Biodiversity and Geodiversity Assets • Issue H6: Pitches and Plots for gypsies, travellers and travelling showpeople The Council notes the following sites close to the Cherwell boundary, which are identified through the Call for Sites consultation: • Lower Tysoe - West, East and North (REFID 544) • Warmington - South - Carpenters Farm (REFID 566) • Mollington Lane Previously Part of Grove Farm (REFID 87) If development is identified in locations close to the district boundary any impacts on Cherwell District should be considered carefully and mitigation provided wherever possible. Cherwell District Council looks forward to continuing our cooperation with Warwick District Council and Stratford-on-Avon District Council, including on the issues and matters identified above, and on strategic cross boundary matters under the Duty to Cooperate as the South Warwickshire Plan progresses.

The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives. The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

I would like to comment on the Local Plan, in particular its stance in relation to the Green Belt around the north of Leamington. There appears to be scant recognition of the five core purposes of the Green Belt, all of which would be compromised by building on it. Other submissions will have made a detailed case against any such development - I would, for instance, wholly concur with the views expressed by Cllr. Gifford - and will simply note here that the value of the Green Belt as a social amenity, community asset, and a haven for wildlife as biodiversity is increasingly eroded should take precedence over the wish of developers to take the easier option rather than look at the potential of urban and brownfield sites.

Reference to development suggested for the area surrounding Henley in Arden. I heavily reviewed the land highlighted. It is clear that these overlay specific land owners land and do not represent any efficient or effective development of land to meet the needs of the SWLP. If using guidance from the latest edition of the Gov NPPF several areas are ignored. Land identified to the South East of the Town around Blackford Mill. Significantly breaches points listed under section 78, 79, 80, 106, 138 A - E. 139, 140 141, 142. This land in fact reaches out into the green belt in a slim finger without contact with any existing urbanization, roads or infrastructure. It clearly joins Henley in Arden to the Village of Wootton Wawen, in contradiction to planning guidance, leaving Wootton Wawen to be swallowed up and loss of identity. Further to that it clearly sits on the flood plane of the River Alne a river clearly defined as having significant impact for flooding in and around Henley in Arden. Further issues regarding access to this land are obvious. In conclusion it is in every way when referencing planning guidance. Inappropriate. Overall the development in and around Henley is so large it will significantly change the characteristic of the town. A town impacted by significant traffic congestion. Any development which is understandable should be to the north of the town where there is brown field and less valuable land. Better linked to the motorway links and closer to the station highlighting the requirements for sustainability under the NPPF. The development around the historic site of the mount similarly inappropriate under the NPPT having significant impact on a n historic monument. This development should be reduced in scale.

Reference to development suggested for the area surrounding Henley in Arden. I heavily reviewed the land highlighted. It is clear that these overlay specific land owners land and do not represent any efficient or effective development of land to meet the needs of the SWLP. If using guidance from the latest edition of the Gov NPPF several areas are ignored. Land identified to the South East of the Town around Blackford Mill. Significantly breaches points listed under section 78, 79, 80, 106, 138 A - E. 139, 140 141, 142. This land in fact reaches out into the green belt in a slim finger without contact with any existing urbanization, roads or infrastructure. It clearly joins Henley in Arden to the Village of Wootton Wawen, in contradiction to planning guidance, leaving Wootton Wawen to be swallowed up and loss of identity. Further to that it clearly sits on the flood plane of the River Alne a river clearly defined as having significant impact for flooding in and around Henley in Arden. Further issues regarding access to this land are obvious. In conclusion it is in every way when referencing planning guidance. Inappropriate. Overall the development in and around Henley is so large it will significantly change the characteristic of the town. A town impacted by significant traffic congestion. Any development which is understandable should be to the north of the town where there is brown field and less valuable land. Better linked to the motorway links and closer to the station highlighting the requirements for sustainability under the NPPF. The development around the historic site of the mount similarly inappropriate under the NPPT having significant impact on a n historic monument. This development should be reduced in scale.

Reading the development of the South Warwickshire Local Plan I discovered that it is proposed to zone an area in Grove Lane Ashow for 10 houses. This I consider inappropriate and include for you reference a letter of objection which I sent in response to the planning application W/17/1530.

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

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. Not only this but development in this area is liable to alter the hydrology of the site closer to the river by creating greater run off and a faster movement of water in the subsoil. This is liable to result in more flooding downstream including that towards the town center of Leamington Spa and beyond. The Climate Emergency can not be used as justification to develop on greenbelt land especially when we have seen so much disruption and damage to biodiversity and habitat as well as on local resident’s lives from developments such as HS2. The development of this land would go directly against every bullet point given in chapter 3.

The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives.