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

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.

Re: South Warwickshire Local Plan – Issues and Options Consultation Thank you for the opportunity to comment on the South Warwickshire Local Plan (SWLP) Issues and Options (IOP) consultation. Bellway Strategic Land (part of Bellway Homes Limited – ‘Bellway’) is promoting land north of Loxley Road, Stratford upon Avon, a site we own freehold and which was previously promoted by Rosconn Strategic Land. The site was submitted through the initial Call for Sites process and has been recorded as Site 471 on the Interactive Map. Bellway have the following comments, which we trust the Councils will find helpful and fully consider in informing the subsequent Preferred Options stage of the SWLP.

Q-S5.2: Do you think new settlements should be part of the overall strategy? No. Bellway understand the rationale for and the benefits of new settlements where there is suitable and deliverable land available for them. For example, there was spatial logic to the Long Marston and Gaydon/Lighthorne Heath new settlements identified through the adopted Stratford District Council Core Strategy as one was partially previously developed land and the other near a strategic employment site. However, the new settlement options identified in the SWLP appear to lack such robust logic. Half are located in the Green Belt and whilst we are generally supportive of releasing Green Belt land to meet development needs where there is a strong sustainability case to do so and where harm to the Green Belt can be minimised or mitigated, the creation of freestanding new communities within the Green Belt will have a considerable impact on its openness. The Green Belt new settlement options also happen to be the only locations which have existing train stations. The other options outside the Green Belt are reliant on new stations being built which is a considerable undertaking and there is no evidence at present to indicate, notwithstanding the size of any given potential new settlement, that these would be viable or could be operationally accommodated in a timely manner within the existing network. Bellway understand the rationale for focusing growth around railway stations and corridors to make best use of public transport options to address climate change, but we consider the same benefits could be achieved through more proportionate release of land around a greater number of existing settlements with rail and other public transport connections. We do not consider that a railway and public transport-led strategy must be weighted in favour of new settlements and there is a lack of evidence to indicate that this is a sustainable or viable option. Issue S6: A review of Green Belt boundaries Whilst Bellway support a general review of Green Belt boundaries, national guidance should be carefully considered to ensure that all opportunities outside the Green Belt are examined fully, as required by paragraph 141 of the NPPF (2021). We agree that avoiding the Green Belt entirely will not generate a sustainable pattern of growth in view of the scale of likely growth required across the 2 Councils, as envisaged by the emerging SWLP.

I have been informed that within proposals for an updated Local Plan that two potential development sites are being considered within the parish of Ashow. I wish to strongly object to both the site along Grove Lane, Ashow and also the potential site for light industrial development opposite Dial House Farm, Ashow (in the field adjacent to Thickthorn Wood). Firstly, both sites fall within the Greenbelt and as such numerous planning applications in recent years have been refused permission because of the Greenbelt status. Ashow village does not have the necessary infrastructure for schemes which could provide a minimum of ten residential properties. Secondly, Ashow village and the surrounding area (much of which is Conservation Area) has already been impacted in a negative way by the current HS2 works and current developments on the south-east of Kenilworth and within nearby Stoneleigh Park. There has been little mitigation against these developments and wildlife habitats (particularly the ancient woodland, Thickthorn Wood) are already struggling. I feel that both of the proposed sites would be perfect ones for preserving the Greenbelt and by further enhancement of new woodland planting. Thirdly, both proposed sites, if they were to be developed would have a detrimental impact upon the setting of numerous Listed Buildings. Fourthly, I would question the ‘actual need’ for such developments in the locations as opposed to the opportunistic financial gains that would be made by the current landowners. I should be grateful if the above points could be considered prior to any commitments being made.

The South Warwickshire Local Plan Revisions indicate that a field in the centre of Ashow village has been put forward for the development of ten or more new houses and we wish to comment on this proposal. The access to the field is from Grove Lane which is a single track road without footpaths set into the landscape with banks and hedges on both sides. The access is very restricted and unsuitable for a development of this size. The necessary widening of the lane and provision of footpaths to service the site would result in the destruction of an attractive country lane and the degrading of an important part of Ashow’s rural character. The existing Local Plan defines Ashow as a village not scheduled for expansion and there has been no change in circumstances that would necessitate housing expansion into this ancient village in the green belt. The massive scale of housing development immediately north of the A46 on the southern edge of Kenilworth will accommodate the housing requirement for that town. While 10 new houses are insignificant in District terms; in a village of 42 houses it would represent a major intrusion and a significant change to the village character. The suggested site is on high land overlooking the core of the village and is one of the least suitable housing sites that could be chosen in Ashow. A practical deficit is that the site lacks access to any main drainage. The proposed WDC plan also indicates land at the Chesford Crossroads north of the B4115 Ashow Road is being put forward for an industrial site; this piece of ribbon development next to the Leamington road would be unsightly and create traffic problems on an important and very busy road linking the A46 to Leamington Spa. We therefore request that these sites are not accepted for inclusion on the Local Plan revision 2023.

1 Introduction 1.1. Context Gladman welcome the opportunity to comment on the South Warwickshire Local Plan Issues and Options consultation and request to be updated on future consultations and the progress of the Local Plan. Gladman Developments Ltd specialise in the promotion of strategic land for residential development and associated community infrastructure and have considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public. Gladman has been involved throughout the plan preparation process of the South Warwickshire Local Plan and previously submitted representations and a Portfolio of Sites to the Scoping Consultation undertaken in June 2021. Gladman Developments have multiple land interests in South Warwickshire within the Stratford-on- Avon District. These include land north of Evesham Road, Shottery; land off Shoulderway Lane, Shipston-on-Stour; land off Southam Road, Long Itchington; land south of Loxley Road, Stratford-on-Avon; and Temple End, Harbury. Gladman are also promoting land at Wellesbourne Airfield, which is addressed in a separate accompanying submission. Gladman looks forward to engaging further with the Council as the plan preparation process progresses. The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is: • Positively Prepared – The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development. • Justified – the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base. • Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and • Consistent with National Policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework. The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan preparation. As demonstrated through the outcome of the 2020 Sevenoaks District Council Local Plan examination and subsequent Judicial Review, if a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend nonadoption of the Plan. Whilst Gladman recognise that the Duty to Cooperate is a process of ongoing engagement and collaboration, as set out in the Planning Practice Guidance (PPG) it is clear that it is intended to produce effective policies on cross-boundary strategic matters. In this regard, the Councils must be able to demonstrate that they have engaged and worked with neighbouring authorities, alongside their existing joint working arrangements, to satisfactorily address cross-boundary strategic issues, and the requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question of effective cooperation. The revised Framework introduced a number of significant changes to how local planning authorities are expected to cooperate including the preparation of Statement(s) of Common Ground (SoCG) which are required to demonstrate that a plan is based on effective cooperation and has been based on agreements made by neighbouring authorities where cross boundary strategic issues are likely to exist. Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process1 . The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for 1 PPG Reference ID: 61-001-20180913 strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with such as unmet housing needs. The South Warwickshire Local Plan will need to consider how it will deal with the issue of unmet needs arising from Coventry, and Greater Birmingham and the Black Country. In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA). Incorporating the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against reasonable alternatives. The Councils should ensure that the results of the SA process clearly justify their policy choices. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the South Warwickshire Local Plan’s decision-making and scoring should be robust, justified, and transparent. The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England and how these should be applied. It provides a framework within which locally prepared plans for housing and other development can be produced. Requiring plans to set out a vision and a framework for future development and seek to address the strategic priorities for the area. Local Plans should be prepared in line with procedural and legal requirements and will be assessed on whether they are considered ‘sound’. The NPPF reaffirms the Government’s commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social, and environmental priorities and to help shape the development of local communities for future generations. In particular, Paragraph 16 of the Framework (2021) states that Plans should: “a) Be prepared with the objective of contributing to the achievement of sustainable development; b) Be prepared positively, in a way that is aspirational but deliverable; c) Be shaped by early, proportionate and effective engagement between planmakers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees; d) Contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals; e) Be accessible through the use of digital tools to assist public involvement and policy presentation; and f) Serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).” To support the Government’s continued objective of significantly boosting the supply of homes, it is important that the South Warwickshire Local Plan provides a sufficient amount and variety of land that can be brought forward, without delay, to meet housing needs. In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach. Once the minimum number of homes that are required is identified, the strategic planning authority should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. In this regard, paragraph 67 sets out specific guidance that local planning authorities should consider when identifying and meeting their housing needs. Annex 2 of the Framework (2021) defines the terms “deliverable” and “developable”. Once a local planning authority has identified its housing needs, these needs should be met as a minimum, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so. This includes considering the application of policies such as those relating to Green Belt and giving consideration as to whether or not these provide a strong reason for restricting the overall scale, type and distribution of development (paragraph 11b)i.). Where it is found that full delivery of housing needs cannot be achieved (owing to conflict with specific policies of the NPPF), Local Authorities are required to engage with their neighbours to ensure that identified housing needs can be met in full (see Paragraph 35 of the NPPF 2021). The July 2021 revision to the NPPF provides greater focus on the environment, design quality and place-making alongside providing additional guidance in relation to flooding setting out a Flood Risk Vulnerability Classification at Annex 3, the importance of Tree-lined streets and amendments to Article 4 directions. Additionally, Local Plans which have not yet progressed to Regulation 19 stage should ensure that where strategic developments such as new settlements or significant extensions are required, they are set within a vision that looks ahead at least 30 years (See paragraph 22). The amendments coincide with the publication of the National Design Guide and National Model Design Code, a toolkit which helps local communities to shape local design needs and provide guidance for creating environmentally responsive, sustainable, and distinctive places with a consistent and high-quality standard of design. The Planning Practice Guidance (PPG) was first published by the Government to provide clarity on how specific elements of the NPPF should be interpreted. The PPG has been updated to reflect the changes introduced by the revised NPPF to national planning policy. The most significant changes to the PPG relate to defining housing need, housing supply and housing delivery performance. In December 2022, Secretary of State for Levelling Up, Housing and Communities, Michael Gove unveiled a raft of proposed planning reforms as part of the Levelling Up and Regeneration Bill. A consultation on proposed reforms to the NPPF, views on an approach to preparing National Development Management Policies alongside developing policies to support levelling up, is open between 22 December 2022 and 02 March 2023. The proposals include revisions to how housing figures should be derived, address issues in the operation of housing delivery and supply tests and several other elements. However, the Government has reiterated its commitment to delivering 300,000 homes a year, with the changes focussed on increasing housing delivery. The consultation document highlights that reforms to the plan-making system are intended to be introduced in late 2024 and the Government have highlighted that plan-makers will have until 30 June 2025 to submit Local Plans for independent examination under the existing legal framework. The South Warwickshire Local Plan should seek to continue the development and preparation of the emerging Local Plan in line with the proposed transitional arrangements. However, given the proposed changes are subject to consultation and potential further revisions, the Councils should be aware of the consultation outcome and possible changes to the NPPF in Spring 2023. 4 Issues and Options Consultation 4.1. Background The Stratford-on-Avon Core Strategy was formally adopted in July 2016 and the Warwick Local Plan was adopted in September 2017. These documents set out the long-term strategic vision, objectives and planning policies to guide development over their respective plan periods. Despite no formal merger of the two Councils, Stratford-on-Avon and Warwick District Councils are working together to produce a new South Warwickshire Local Plan to cover their combined geographic area. Stratford-on-Avon and Warwick District Councils are currently undertaking an Issues and Options Consultation and Call for Sites, for a period of 8 weeks between Monday 9 January - Monday 6 March 2023. The Issues and Options consultation provides a second opportunity for residents and stakeholders to have their say on the emerging Local Plan and will include different options for selecting preferences to several planning policy issues and the policy options to address them. It also sets out broad options for consideration on where to best accommodate new development in the future. Gladman support the Council’s timescales relating to the new Local Plan as set out in the Local Development Scheme published in December 2022. The sections that follow below include specific comments from Gladman covering a range of the topics and questions that have been posed.

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? 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 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? 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, and the level of facilities within the settlement. For example, the location of a secondary school at Kineton is indicative that a higher level of growth would be appropriate to support the long term viability of the school. The threshold should not therefore be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire with regard to brownfield development. Gladman consider that Option S3.2a is the most suitable approach to brownfield development. Gladman support the delivery of brownfield development, but the Councils should be mindful that these sites are not without complication. They can typically incur high development costs and therefore are not always viable. This can in turn impact affordable housing provision and the provision of other community benefits that greenfield sites can typically deliver without significant issue. Q-S5.2: Do you think new settlements should be part of the overall strategy? As previously stated, Gladman are not against the allocation of new settlements, however they should not be used as the sole method of delivery due to the known complications and delays sites of this scale can incur. Rather, a new settlement should be considered as part of a dispersed spatial strategy that allocates a range of sites. Q-S9: Please select the option which is most suitable for South Warwickshire with regard to settlement boundaries. Gladman consider it would be premature to define the settlement boundaries without considering allocations for residential development in settlements, adjacent to the existing boundaries. Irrespective of when the settlement boundaries are considered, be it in Part 1 or Part 2 of the plan, the policy should contain a mechanism to ensure the development beyond the settlement boundary can come forward should other allocations not deliver as expected and the supply drop. This will allow the Plan to respond effectively to changes in circumstance throughout the plan period and ensure that much needed market and affordable housing can be provided. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire. Fundamentally, Gladman consider that the spatial strategy needs to be balanced and supported by a clear settlement hierarchy. A balanced approach will increase choice and competition for housebuilders and buyers and increase the likelihood of the housing requirement being delivered within the plan period. It also allows a range of settlements to benefit from the benefits of development, such as affordable housing, community benefits and S106 contributions.

Q-S2: Please select all options which are appropriate for South Warwickshire Option S2b: Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes. This would provide a policy basis for intensification to come forward, where suitable, with guidance from generic design code, which would set the standard for the quality of development but still allow the design of development to respond a specific site location and context and local needs. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Option S3.2c: None of these The Urban Capacity Study has identified a significant shortfall of 7,400 dwellings therefore it is clear that a combination of brownfield and greenfield sites will need to be relied on in order to meet the needs of the Plan area (and what may be required from the adjacent Housing Market Areas). A policy to prioritise only brownfield land is therefore likely to hinder development coming forward on greenfield sites when it is vital that they come forward, and in a timely manner, to meet local need. On this basis, we consider that neither of the options to prioritise brownfield development are appropriate in this circumstance, and the absence of recognition that MRC’s, especially those that are non-Green Belt, are both sustainable locations with good sites available for this purpose. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, especially Kineton where it is not in Green Belt, has suitable sites, and has taken the least growth of any MRC. Q-S9: Please select the option which is most appropriate for South Warwickshire It is not considered that either of the options suggested are appropriate. Settlement boundaries should be reviewed and, where appropriate amended, as part of both the Part 1 and Part 2 Plan processes. There is a clear need to review boundaries to take account of strategic allocations as part of the Part 1 Plan process. However, this does not mean that boundaries cannot be reviewed again in respect of non-strategic allocations during the Part 2 process, as alluded to within the options provided. In the interim whilst awaiting the Part 2 Plan boundary reviews, it is considered that there would be a negligible impact on differing approaches to remaining settlement boundaries within the separate Stratford-on-Avon and Warwick Local Plans. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire Kineton is a sustainable settlement with a number of existing facilities and amenities (including a post office, village hall, public house, bakery, café, sports and social centre, garden centre, co-op, restaurants, various shops, surgery, vets, primary school and secondary school) as set out in our accompanying Vision Document. Kineton also has a good network of movement routes, including a range of public transport services within easy access. There are also regular bus services providing access to Leamington Spa, Banbury, Wellesbourne and Stratford-upon-Avon. Under the current Local Plan, it has not taken anywhere near the same quantum of development as other villages of comparable status. It is not Green Belt; it is in a sustainable location with a good range of local services and facilities and the Neighbourhood Plan is now nearly 7 years old and s hould no longer provide protection against meeting future housing need. Kineton is identified as a Main Rural Centre in the Adopted Core Strategy. As already stated, there are other Main Rural Centres which are Green Belt and there are numerous Local Service Centres (third tier settlements) which are constrained by environmental designations such as the Cotswolds AONB, Special Landscape Areas and Conservation Areas. To provide further context, the settlements of Alcester, Studley and Henley -in-Arden are constrained by the Green Belt. Kineton has no such designation however, it has a disproportionately lower level of proposed growth compared with similarly sustainable villages, and indeed the less sustainable ones. Site Selection Process A SHLAA update was published in April 2020. The update replaces the previous SHLAA published in 2019. The Site Evaluation Criteria sets out the three key stages of assessment – Suitability, Availability and Achievability together with the criteria for each stage. In the case of Kineton, the two proposed reserve sites identified as “safeguarded” land as identified in the KNP (to be released for up to 200 dwellings if further housing need arose) were necessarily assessed in considerably more detail than the NDP process undertook to reserve them for this capacity. This process identified that these sites were very sensitive in landscape terms, more so than other potential sites in the village such as Sites 7 and 8, and also scoring much lower on many other counts and overall. The SHLAA scoped down the development potential of those reserve sites down to just 60 (site 4) and 45 (site 5) dwellings, leaving a shortfall of some 95 dwellings on what the KNP envisaged as reserve housing capacity of the village. With sites 7 and 8 being assessed as available and more sustainable, it is only logical that even within the confines of what the NDP envisaged to accept as growth, irrespective of the SDA, that they are considered suitable to “balance up” the reserve allocation of housing for the village which should accept more growth as envisaged by the KNP. Assessment of SHLAA site 7. Sharba Homes site is identified as Site 7 on the Kineton Land Parcel Map. The site is broadly square in shape and extends northwards from Banbury Road. The parcel is currently in arable use and contains some limited built form, consisting of areas of hardstanding, gravel tracks, a metal building housing radio receiving equipment along with a separate PMR mast, pylons for overhead High Voltage electricity cables and some sheds. An existing vehicular entrance is located along Banbury Road, extending along the eastern boundary of the parcel and provides a farm connection to the agricultural fields to the north and to a single adjacent farmhouse. At present, there are no Public Rights of Way which run through the Site. Due to the arable use of the Site, there is limited vegetation. This is confined to the boundaries and comprises semi-improved grassland margins, existing trees and hedgerows. There are no listed buildings located within, or directly adjoining the Site. It is noted that the registered Battlefield of Edgehill (List Entry 1000009) extends to the south of Banbury Road. The Site is located wholly within Flood Zone 1, an area which has the lowest possible risk from flooding (i.e. less than a 0.1% chance) – as confirmed by the Environment Agency’s consultation response to the application. Surrounding Area The Site is contained along the majority of three boundaries by the existing built form of Kineton. This includes Kineton High School (and associated development) to the west and residential dwellings to the east and south. It is noted that the residential properties to the east, located at Walton Fields, extend only part-way along the boundary of the Site. Agricultural fields extend to the east of the Site from the northern section. Similarly, along the western boundary, the built -form of Kineton High School only extends partway along the Site. However, playing fields set out as a variety of sports pitches associated with the school run alongside the western boundary of the Site. It is noted that the sport pitches include a newly constructed artificial playing pitch along the north-west boundary of the Site with high metal fencing and 15m high floodlighting. Site Suitability The Council will be aware that the Site was dismissed on appeal in 2016. However, the site area was double the size of that currently proposed and indeed, there are several factors which now warrant consideration of this Site in the context of a revised smaller scheme. It is noted that the 2020 SHLAA also considers the potential for a smaller site area the size of that currently being promoted. The Site is identified in the SDC Landscape Sensitivity Study 2011 as a possible location for development, at a scale which is now being submitted for consideration. A detailed assessment of the site was undertaken in the context of a Landscape Sensitivity Assessment (LSA). It is deemed to lie within a pattern of small to medium scale regular fields in mixed agricultural use amongst trimmed, or sometimes outgrown, hedges and scattered trees. There are distant views towards Edgehill to the south-east and, beyond the local ridge, to the higher sylvan ridgeline that ends at Pittern Hill (to the north-west) forming a sylvan backdrop to the local skyline. The main sensitivities derived from the immediate surroundings are described as the stream corridor and associated ridge and furrow fields, the minor ridge skyline to the north-east and the openness of the countryside to the north and east. It is suggested that there is potential for housing along Banbury Road between the college and the cul-de-sac at Walton Fields, but no further north than the latter to ensure that the settlement edge if ‘stepped and well below the minor ridge top’. The revised scale of development that is proposed and assessed in the SHLAA, remains on the lower contours and stops short of the rise in topography that typifies the northern half of the site to comply with this constraint to the limited form of development that is assessed as suitable by both the LSA and SHLAA and as quoted by the Parish Council. Indeed, the LSA identifies the site as the only “medium sensitivity” landscape around Kineton, the rest being “high sensitivity”, and is a particularly rare occurrence of that lower sensitivity in any village. With regard to any potential conflict with the more detailed policies within the Kineton NP, the site area has been reduced from that assessed previously to also ensure that none of the site falls within the ‘Valued Landscapes’ policy (E2) as identified in the Kineton NP. Paragraph 12.9 of the Inspector’s Report confirms that the key issue previously was the protrusion above the local ridge line by virtue of the proposed dwellings on the higher slopes. It was considered that this would form a discordant edge to the settlement. These matters are completely removed with the revised scheme put forward and thus the previous concerns have been overcome. The appeal Inspector concluded that the proposal would not alter the setting of the battlefield sufficiently to adversely affect the significance of the registered battlefield site. It is therefore simply incorrect to identify ‘non designated heritage’ assets as a ‘red’ constraint to development , an Appeal decision of ‘no adverse effect in this regard should in fact render this a matter “green” . A further note in this regard, the land on the opposite/south side of Banbury Road, between the subject site and the battlefield, was considered suitable for a housing allocation despite being closer to the battlefield. There are only two ‘amber’ sites identified within the village in the SHLAA. The other ‘amber’ site is the land immediately adjoining the eastern boundary of Site 7. However if a simple ranking exercise were undertaken, while both sites have the same number of ‘green’ elements (i.e. elements which make the site ‘definitely deliverable ’), Site 7 has only two ‘red’ elements (although these are disputed as above), Site 8 has 4 ‘red’ elements, and would be “isolated” if developed on its own. Site 7 is also closer to the village centre and therefore more locationally sustainable than any other possible suitable sites in Kineton. Kineton is also the closest MRC to the growth areas of Gaydon/Lighthorne making it again the most suitable MRC to target for growth, especially given how little it has taken in recent years as set out above. On this basis, it is self-evident from the Council’s own evidence base that Site 7 is the most sustainable site in Kineton, would make up the reserve allocation shortfall, and assist with the overall Plan shortfall. We firmly believe that the site is capable of accommodating a scheme of 40-50 dwellings at a density which is compatible with the character of the surrounding area and which respects existing policy designations. As detailed above, we would recommend the Council proceed with a dispersed approach to housing across the Plan area to ensure that all sustainable settlements will have an opportunity to grow and support their services and facilities. This will also ensure that much needed affordable housing is dispersed across the Plan area, including the more rural settlements, in accordance with the NPPF. In addition, there is also a clear need for greenfield sites (in addition to brownfield sites) to come forward in order to meet the recognised housing need, and suitable greenfield sites such as Banbury Road in Kineton would enable housing to come forward in a sustainable settlement and grow and support their services and facilities.

Q-S2: Please select all options which are appropriate for South Warwickshire Option S2b: Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes. This would provide a policy basis for intensification to come forward, where suitable, with guidance from generic design code, which could set the standard for the quality of development but still allow the design of development to respond a specific site location and context and local needs. Option S2b – not enough land in urban capacity study. Does it identify my two settlements as some inconsistency. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Option S3.2c: None of these The Urban Capacity Study has identified a significant shortfall of 7,400 dwellings therefore it is clear that a combination of brownfield and greenfield sites will need to be relied on in order to meet the needs of the Plan area (and what may be required from the adjacent Housing Market Areas). A policy to prioritise only brownfield land is therefore likely to hinder development coming forward on greenfield sites when it is vital that they come forward, and in a timely manner, to meet local need. On this basis, we consider that neither of the options to prioritise brownfield development are appropriate in this circumstance. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, especially Bishops Tachbrook where it is a larger settlement not within Green Belt and has suitable sites that could come forward. Q-S9: Please select the option which is most appropriate for South Warwickshire It is not considered that either of the options suggested are appropriate. Settlement boundaries should be reviewed and, where appropriate amended, as part of both the Part 1 and Part 2 Plan processes. There is a clear need to review boundaries to take account of strategic allocations as part of the Part 1 Plan process, However, this does not mean that boundaries cannot be reviewed again in respect of non-strategic allocations during the Part 2 process, as alluded to within the options provided. In the interim whilst awaiting the Part 2 Plan boundary reviews, it is considered that there would be a negligible impact on differing approaches to remaining settlement boundaries within the separate Stratford-on-Avon and Warwick Local Plans. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire Bishop’s Tachbrook is a sustainable settlement with a number of existing facilities and amenities (including local shops, surgery, primary school and public house) as set out in our accompanying Design and Access Statement. Bishop’s Tachbrook also has a good network of movement routes, including a range of public transport services within walking distance. There are also regular bus services providing access to Leamington Spa, Banbury, Wellesbourne and Stratford -upon-Avon. As detailed above, we would recommend the Council proceed with a dispersed approach to housing across the Plan area to ensure that all sustainable settlements will have an opportunity to grow and support their services and facilities. This will also ensure that much needed affordable housing is dispersed across the Plan area, including the more rural settlements, in accordance with the NPPF. In addition, there is also a clear need for greenfield sites (in addition to brownfield sites) to come forward in order to meet the recognised housing need, and suitable greenfield sites such as Oakley Wood Road in Bishop’s Tachbrook would enable housing to come forward in a sustainable settlement and grow and support their services and facilities.

Option S2-C: Intensification 19. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Bloor Homes consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 20. 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.

Option S2-C: Intensification 10. 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. 11. 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: Settlement Threshold 34. 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-S8.1: Appropriate limit for individual sites 35. 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 level of facilities.

Option S2-C: Intensification 17. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Bloor Homes consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 18. 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.

Option S2-C: Intensification 8. 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. 9. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? 36. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, 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-S8.1: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 37. Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the size and availability of suitable land identified. 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 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? 39. 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? 40. 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: Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced Utilising Information from the soon to be updated, Sub-Regional Green Infrastructure Strategy and additional evidence obtained in consultation with Green Infrastructure Stakeholders, should the South Warwickshire Local Plan identify Green Infrastructure corridors which can be used to help determine the growth strategy. There should be sufficient existing technical evidence already available to identify the corridors. There would also be scope for these to be modified, as necessary as the local plan progresses. If this approach is taken it is important that maps and images are at a scale and have sufficient clarity so that the status of specific land parcels can be distinguished. Option S1b: Do not identify Green and Blue Corridors within the South Warwickshire Local Plan, and instead rely on the production of the Local Nature Recovery Strategy Instead of identifying Green and Blue Corridors within the South Warwickshire Local Plan, this option will rely on the production of the Local Nature Recovery Strategy. The production of a Local Nature Recovery Strategy will likely come after the SWLP Spatial Growth Strategy has been determined, therefore it is likely that there will be a reduced synergy. It seems unlikely that the scope for any reduced synergy would be very significant and, as mentioned above, there is scope to reduce that as the local plan progresses towards adoption. Q-S2: Option S2b would appear to be the most realistic, and achievable option. It is of some concern that the consultation document identifies some of the potential climate change benefits that can arise from intensification while at the same time failing to recognize potential dis-benefits such as adding to congestion in already congested areas and undermining the character and appearance, as well as the attractive of urban areas though over-intensification. In addition, since all development should be carbon-free by 2050 the differential impacts on climate change between different locations should be significantly reduced.The plan appears to be predicated on a principle that development in urban areas is preferable in climate change terms that development elsewhere. This appears to be a principle based on assertion rather than definitive evidence. It could lead to the degradation of attractive urban environments which would be counter-productive. Q-S3.2: Option S3.2c: None of these These options and the analysis behind them appear somewhat confused and focused towards urban concentration. As highlighted earlier in this response, the evidence to conclusively prove those options are the most sustainable and have the least impact on climate change and CO2 reduction is based more on assertion rather than on conclusive evidence. We also feel that the term 'prioritise’ may not be the most suitable, not least because of its uncertain meaning. Perhaps ‘make best use of’ would be a better terminology. Q-S7.2: General comments: It is likely that the preferred approach will embrace elements from all the options, including dispersed growth. It is also noted that the analysis of growth options appears to exclude consideration of developments smaller than 50 dwellings. While it is clearly the case that such developments, in themselves, would not be strategic but collectively they could have a significant positive strategic impact by reducing pressure for large-scale land development elsewhere. The SA of the 5 Growth Options has been carried at a high level and the conclusions made have been used to rank the dispersed growth option at lower level. It would seem that those conclusions are not sufficiently justified as illustrated by frequent caveating in the analysis. It is also noted that each of the options take forward existing commitments. There is no issue with this, but it would have been helpful to distinguish which elements of each option was committed, so the differences between them could be more easily seen. There is also some concern that the options are biased in favour of large-scale growth. Our interpretation is that each option includes 11 strategic employment allocations of 30 ha or more. This would mean that the whole of the employment land requirement would be allocated through strategic site allocations. Where is the rationale for this? The strategy should allow for the creation and growth of dispersed and rural employment opportunities leading to less concentration and thereby less congestion and better air quality. Q-S8.2: A 10 dwelling limit generally seems appropriate although any such limit should also be caveated to enable developments of more than 10 dwellings in exceptional circumstances or where criteria have been met in terms of sustainability and perhaps provision of additional infrastructure, otherwise potential developments of 11-49 dwellings which might be acceptable on all other grounds would have been excluded from the local plan process. Q-S9: The development strategy should enable a proportion of development to come forward outside strategic sites with a capacity of 50 or more dwellings. The scale of small scale dispersed growth should be disaggregated across the plan area to provide the basis for Neighbourhood Development Plans and the review of settlement boundaries where this is necessary. However, it is important that identification of suitable sites is not unduly delayed and the potential identification and release of an appropriate scale of development where sites have been taken through the Call for Sites should not be unduly delayed. Ideally, where it is known that settlement boundaries require amendment then these settlements should, at the very least, be identified in the plan. If, having identified these settlements then it should be accepted that land might be released adjacent to the extant development boundary. This would provide a strong incentive for Neighbourhood Development Plans and or Site Allocation Plans to be put into place. Q-S10: The level and distribution of growth should be clearly set out in the plan to provide a sound basis for Neighbourhood Development Plans.

I understand that the ‘cut-off’ for observations in respect of the above plan is scheduled for today. Please therefore accept this hurried response. There are two sites in Ashow which appear to be designated for development. I record the following observations respectively: Residential properties off Grove Lane: (a) Congestion: It appears that the development would allow for 10 or more houses. I oppose this suggestion since it would increase size of the village by at least 10% - 20%. Access from the B4115 and through the narrow village road to and then on Grove Lane is already at capacity. Grove Lane itself does not permit traffic to pass abreast in any event. The increasing reliance on home deliveries (of consumer goods and groceries) causes difficulty to movements for existing households, and an increase in traffic by the stated percentage together with peripheral movements to service the enlargement of the village would be intolerable. (b) Infrastructure: Ashow is not on mains drainage. There is no capacity for 10 or more dwellings together with drainage needs. (c) Environment: I suggest that Ashow is itself a fragile environment. The character of the village cannot be maintained if such a substantial incursion is approved. (d) Transport: There is no access to public transport within or immediately adjacent to the village. The nearest bus route is on the A452 at the 'Chesford' crossroads. Thus, the development of this nature will be aimed at purchasers who themselves have one, or more probably two, cars per dwelling. Mathematically, the one village road cannot tolerate the increase of at least 20 cars and their movements without damage to the environment and danger to pedestrians. (e) Need: Substantial (one might say enormous) housing development is taking place on 3 sites adjacent to Ashow: They are found at Glasshouse Lane, Crewe Lane and Thickthorn. The building of many hundreds of dwellings, which include an entirely new school, is already contributing enormous development to this area (in addition to the development of thousands of properties at Kings Hill, which has already been criticised in Parliament) ). It is not possible to identify the need for much of these developments and the environmental demands that they will make on the locality. I respectfully suggest that the need for the expansion of the village does not exist. Light Industrial use opposite Dial House Farm: (a) Current use: The proposed change is simply not understood. The land between the B4115 and the A46 is currently under agricultural use and forms a natural, green, barrier. The appropriateness, let alone the need, for a commercial development on this land appears to have no justification. Commercial development in Kenilworth is sited in defined areas of the town. It is there that any further ‘light industrial’ exercise should be considered.I sense that once the area, however small, is developed in this way, commercial development will ‘creep’ along the B4115, leading to further wholesale destruction of the green belt. (b) Movement of commercial traffic from the A452 onto the B4115 is at its limit already, and the configuration of that part of the B4115 (which is a ‘blind’ bend) militates against an access point opposite Dial House. Substantial road re-alignment (and the resulting damage to the existing area) would be required if there were to be any, let alone ‘light industrial’ development on the designated area.

ISSUE S1: GREEN & BLUE CORRIDORS Q – S1: Please select the option which is most appropriate for South Warwickshire Whilst the focusing on green and blue corridors is one way of considering Spatial Growth, there is no reference whatsoever to the need to consider Economic growth and the benefits of economic growth in those corridors. This is particularly helpful in identifying recovery areas and linking that back to economic growth. Economic growth can provide very substantial Green infrastructure particularly in proper and reasonable balanced Masterplanning of development. Comment on the options Firstly this is a poorly worded question because what is required is a new policy that links Environmental protection, environmental enhancement and economic benefits flowing from development that would both assist protection and enhancement. ISSUE S2: INTENSIFICATION Q – S2: Please select all options which are appropriate for South Warwickshire There needs to be a clear policy context between major urban areas and rural settlements where the issues of density are both fundamentally different. Each site has to be judged on its own merits and the benefits that it could bring with economic growth, employment and sustainable electrical charging points for lorries, vans and cars which needs to be properly balanced against environmental protection and enhancement. ISSUE S7: REFINED SPATIAL GROWTH OPTIONS In requesting consultees to choose one of the five listed options there needs to be a new option focusing on sustainable travel, economy employment and road corridors. Q – S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire Please see our answer above to Issue S7. This is a much better planning approach to growth and sustainability as we have indicated in Issue S7 above. ISSUE S10: ANY OTHER DEVELOPMENT STRATEGY ISSUES Q – S2: Please add any comments you wish to make about the development distribution for South Warwickshire As mentioned at the start of our representations, there should have been a development strategy focusing on the M42 and the landholdings in that area that form part of this emerging South Warwickshire Local Plan.

I refer first to the proposal to build 10+ houses on the field behind the Long Row houses. There are approximately 40 houses in the village proper (excluding Dial House Farm and the house in Rocky Lane). In the early 1970’s the Stoneleigh Estate sold off several properties to a local developer, who demolished some and refurbished others, together with building about 10 new properties. Since then the Planning and Conservation departments of WDC have exercised considerable control over development within the village so as to maintain this balance and thus the character of the village. The proposal to build 10+ new houses is totally out of scale and would change the character of the village irreparably. It would also render meaningless both the Green Belt considerations and more particularly the Conservation area. On a recent application within the village, we were given to understand that one of the considerations in granting consent was that “it was outside the village envelope”. Does this envelope exist? There are also serious practical difficulties, in that there is no foul sewer and, access would have to be via Grove Lane. This lane, which is bounded on both sides by a high bank, originally only provided the access to a farm house, a cottage and a number of agricultural buildings. Subsequent building and the conversion of redundant agricultural buildings have increased the traffic to a point where the lane just copes. The lane is not wide enough for 2 vehicles to pass easily and any delivery by a large vehicle blocks the road. Widening the road is not feasible without destroying the banks and the ancient hedges which are above them. The egress from Grove Lane is also not ideal, having a very poor visibility splay to the right. I suggest this proposal in totally inappropriate and should be rejected. The other proposal to build a light industrial estate on the field to the North of Dial House farm is, in my view, also inappropriate and should be rejected. Once development takes place of the South side of the A46 Coventry/Warwick by pass, the encroachment will continue until Leamington, Warwick and Kenilworth become joined in one urban sprawl. It is also against the spirit of reducing the carbon footprint to have people travelling to work out of towns into the countryside, other than for agricultural work.

Q-S3.1 - Urban Capacity Study: We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority. Q54.1 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 are 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 Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

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 areis ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas 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.

Wootton Wawen held a E.P.M. to discuss the SWLP concept at the beginning of February 2023. The discussion and public forum session set out to outline the SWLP publication and consider specifically it’s impact on Wootton Wawen as a village. Over 74% were in favour of numerous small developments (maximum to 15 homes per site). • The main concern raised were: • The impact and potential destruction of the Green Belt. • This was seconded by the lack of affordable housing, considered vital to bring back to the village the younger generation and particularly young families. • A distinct lack of infrastructure, speeding traffic, general concerns about highway safety (lack of safe road crossing points), an increase in traffic on village roads, lack of leisure and open recreational space were the other main concerns raised. Therefore we would wish to present to the SWLP team the following statement:- Wootton Wawen as a parish are broadly in support and accept that a degree of new housing is required. Indeed our own Neighbourhood Plan 2011-2031 clearly highlights there is a ‘local need for community driven new development’. Emphasis is being placed at the present time on trying to encourage the younger generations, particularly those with school aged children into the village. Our population is an aging one, with approaching 50% of our residents living in the Park Home estate that is Wootton Hall. Over 51% of those present indicated that it was felt acceptable to support the development of approx. 100 houses within the village over the span of the plan (i.e. to 2050). The Local Neighbourhood plan already highlights this need. Up to 100 homes over the span of the SWLP (to 2050) would it is felt be an acceptable number, providing that these decisions are able to be taken at a local (parish) level regarding the where, when, how many, housing mix, etc. This would ensure that the unique environment that is Wootton Wawen is preserved, and local knowledge and support maintained. Over 72% were in favour of using an area as identified (4) specifically as the basis for any development. There is very little brownfield in-fill land available within the parish, and it is bounded and protected on all sides by Green Belt land. Just because there is a railway station in the village should not immediately target Wootton Wawen for any form of large-scale development. The train station and the surrounding area cannot currently support any significant infrastructure development. At present it does not even have space for a car park. The infrastructure is simply not in place currently to support any meaningful expansion, and space to do so is very limited and restrictive. Wootton Wawen is surrounded and indeed protected by Green Belt and any incursion into this land should be very carefully considered. The village has a scheduled monument, considerable and varied listed buildings, as well as benefits from both woodland, canal, river and valley views. All need to be carefully considered around any potential future development, hence the need for local knowledge and local decision making being a priority. Wootton Wawen has an ambitious vision with a project designed to support and provide a new replacement school (the existing school is over 50 years old and in need of considerable work to maintain it). It is envisioned that this new building and surrounding recreational area, could become a community hub, with it is hoped a provision to support such services as a GP satellite surgery, and locally needed support services. There is a significant level of sustainability and most importantly a carbon-neutral setting. Our neighbourhood plan (2011-2031) already details the needs to greatly enhance provisions for the younger generations, and to actively support and welcome them back to Wootton Wawen. With it’s extensive (almost 300 units) park homes estate, the demographic of the village is skewed on its data as approaching 50% of the homes recorded are on this estate.This concept has been in place for some time, and it may well be that with the support and carefully considered development within the village, it will be possible for this to be supported by developers, as well as planners and provide real benefits and bring about a long term level of sustainability for both current and future village residents.

I am writing in response to the South Warwickshire Local Plan Consultation on behalf of Offchurch Parish Council. I request you accept these responses to inform your consultation process: The Offchurch Parish Council (OPC) object to any further development being considered in Offchurch Village, which is a Conservation and a limited infill area. Two of the sites are on or close to School Hill which is a highly visible area of the Village and if allowed these sites would significantly change the appearance and character of a key part of the Village. One of the nominated sites has already been the subject of a planning application and was opposed by the Parish Council and was rejected out of hand by Warwick District Council. OPC would be very concerned should the site be now eligible for development, given the overwhelming opposition to such a development. The infrastructure of Offchurch does not lend itself to allowing multiple sites being developed. Without wholesale changes the Village is incapable of supporting multiple sites being developed for new houses. We would contest that it is unacceptable to consider the development of a new settlement within greenbelt land, such as Offchurch, there are no exceptional circumstances to justify so doing. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. We also consider any further sites within Offchurch put forward in the second call for sites would fall into the above opinion. Offchurch has been significantly blighted and the landscape changed dramatically as a result of HS2. Further loss of greenbelt and development in Offchurch would impact adversely on residents.

Issue S10 - I have concerns about the forecast housing needs, given the major uncertainty of any current forecasts.

DEVELOPMENT DISTRIBUTION STRATEGY FOR SOUTH WARWICKSHIRE ISSUE S1: GREEN & BLUE CORRIDORS Q – S1: Please select the option which is most appropriate for South Warwickshire Whilst the focusing on green and blue corridors is one way of considering Spatial Growth, there is no reference whatsoever to the need to consider Economic growth and the benefits of economic growth in those corridors. This is particularly helpful in identifying recovery areas and linking that back to economic growth. Economic growth can provide very substantial Green infrastructure particularly in proper and reasonable balanced Masterplanning of development. For instance, at Junction 3 of the M42 on the north-east corner the facilities that we are proposing can be set within a strong green and landscaped environment for the benefit of all persons including those using the budget hotel. Comment on the options Firstly this is a poorly worded question because what is required is a new policy that links Environmental protection, environmental enhancement and economic benefits flowing from development that would both assist protection and enhancement. ISSUE S2: INTENSIFICATION Q – S2: Please select all options which are appropriate for South Warwickshire There needs to be a clear policy context between major urban areas and rural settlements where the issues of density are both fundamentally different. Each site has to be judged on its own merits and the benefits that it could bring with economic growth, employment and sustainable electrical car charging points which needs to be properly balanced against environmental protection and enhancement. ISSUE S7: REFINED SPATIAL GROWTH OPTIONS In requesting consultees to chose one of the five listed options there needs to be a new option focusing on sustainable travel, economy employment and rail corridors. Q – S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire Please see our answer above to Issue S7. This is a much better planning approach to growth and sustainability as we have indicated in Issue S7 above. ISSUE S10: ANY OTHER DEVELOPMENT STRATEGY ISSUES Q – S10: Please add any comments you wish to make about the development distribution for South Warwickshire As mentioned at the start of our representations, there should have been a development strategy focusing on the M42 and the landholdings in that area that form part of this emerging South Warwickshire Local Plan.

Q S.1Please select the option which is most appropriate for South Warwickshire 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 QS5.2 Do you think new settlements should be part of the overall strategy? 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 privatesector 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. QS5.3 In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? 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. QS7.2For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire:: The SWLP has effectively offered Henley/ Beaudesert no option. The growth levels in all five options for the town are identical. The outcome for the town in practice could be the same whichever one(s) are supported. The residents therefore would expect to see options which are better defined, more granular and phased in shorter periods. A successful plan is very likely to be a mixture of all of the development options set out. The main problem with the options is that three of the five criteria are tied up with transport and connectivity, but transport and other links are not binary factors. A clear example of this is the difference between a railway service between Henley in Arden and Birmingham and Warwick or Leamington spa and Birmingham. A journey between Henley and Birmingham takes 40 minutes (on timetable) and occurs once an hour but a journey from Leamington or Warwick takes 30 minutes twice an hour and has London services not available in Henley. Similarly there have been recent reductions in bus services between Henley, Coventry and Stratford, which threaten to make connectivity significantly worse. This is not a problem restricted to Henley but also affects other possible growth centres and villages. This fundamental issue must be addressed and fully consulted on before a Preferred Development Option is decided upon. QS8.1 For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Outside the settlements the Countryside Policy should prevail. Inside the settlements the size should be in accordance with the Neighbourhood Plan and appropriate to the nature of the specific sites QS.10: 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)

S1 -Green & Blue Corridors We support Option S1a to identify Green & Blue Infrastructure Corridors now in advance of other information becoming available. It is essential that these corridors be identified now on the basis of existing information as they are strategically important elements to consider when assessing other elements of the Local Plan. (The corridors adjacent to and within settlements have been identified as part of the Settlement Analysis, but important corridors in the open countryside also need to be identified) S2 – Intensification (density) The feedback from the first consultation and associated commentary in the current consultation document provides compelling reasons to have strong policies to support intensification. These include increasing active travel, maintaining local services and reducing the need to build on greenfield sites. We support Option S2a: (Identify areas considered particularly suited to intensification development, and develop a design code for each character area.) This is appropriate as there cannot be a successful generic design code which applies to each location. S4- growth of existing settlements Q-S4.1: We support the growth of some of our existing settlements, as long as the proposed development land complies with the principles of the “20-minute neighbourhood “. If existing settlements do not yet have facilities, we support the extension of them as long as new facilities are provided which follow the principles of the “20-minute neighbourhood “ and do not have a significant impact on the area’s landscape character. It is essential that these new facilities are completed before other development takes place. When planning the growth of existing settlements it is important to ensure an engagement of existing local residents in the design process. Presenting an architect’s plan as a fait accompli is not the way forward. Consideration should be give to the use of a process using a ‘Design Charette’ or ‘Enquiry by Design’ both of which are planning tools that brings together key stakeholders to collaborate on a vision for a new community. Q-S5.2: We support the principle of new settlements being part of the overall strategy, as long as the proposed developments comply with the principles of the “20-minute neighbourhood”. Q-S5.3: We support the principle of rail corridors being one factor to consider when assessing the location of a new settlement. However, other factors should be considered such as the impact on landscape character. Apart from their locations along railway lines, the potential settlement locations shown in the document appear to have been chosen at random, with no other justification. On Figure 12, the existing rail lines identified on the map have different characteristics. C, D, and F are part of the main-line network and connect into the national system at both ends, the others are branch lines that connect only at one end, so the journey opportunities are more limited. Also, E and G are freight-only, stub-end lines, whose infrastructure is probably not suitable for a passenger service without major investment. The siting of ‘F3’ (on the railway line near Fenny Compton) does not match with the wording in table 5 as ‘GLH Gaydon Lighthorne Heath’ (which is not on a rail line). Please clarify. Figure 12 and Table 6 shows ‘A1’ in the area of Wood End/Tanworth in Arden, yet it is referred to as ‘Henley in Arden’ in table 5. In table 5, Wood End is identified as ‘F1’, yet this is shown as near Harbury on Figure 12. Please clarify. The landform / significant changes of level in the Tanworth in Arden area would make it very difficult to fit in new development without severely affecting the landscape character. In contrast, a location at Earlswood Station would appear to be a sustainable possibility as it is a flat site next to a motorway as well as the railway, but this does not appear on the list. S6- Green Belt We support development in the Green Belt in locations which are sustainable – i.e. can follow the principles of the “20-minute neighbourhood “. S7 – Spatial Growth Options To describe them as Options implies selecting one of them. In reality, the preferred way forward is likely to be a combination of them, but using the Vision and Strategic objectives (page 21) to guide selection. Option 5 (Dispersed) is the least favourable option as it would perpetuate the need for individual travel, particularly by car. We would hope that the strategic objectives would be to prioritise available resources on enhancing and expanding those settlements large enough to be significantly self-sustaining with houses, jobs, schools, communications, transport links etc., whilst "stabilising" other, smaller settlements. The Vision and Strategic objectives, coupled with available funding, must have rational outcomes. We think the description of options needs to be followed by a summary of the implications for each settlement location noted. Some of the locations will come across as having strong development potential because of viable existing, and potential, transport opportunities whilst others will not. Figures 14 and 15: Do the graphs include the embodied energy expended in construction, or just the ongoing emissions? Construction uses a lot of energy/generates a lot of CO2 (e.g. concrete), and is an up-front impact. We would have expected to see some early peaks in the graph. S8- Small scale development We support limited infill within settlement boundaries. This is a well established and successful strategy. We also support small developments adjacent to existing settlements as long as the new developments follow the principles of the “20-minute neighbourhood “. S9 – Settlement boundaries We support settlement boundaries for all settlements and adjustment to existing boundaries where necessary as noted above. Defined settlement boundaries give certainty to all affected. However these boundaries need to be informed by the Green Belt Study and Landscape Character Assessment. S10 -Other development strategy issues The plan should include a strategy for integrating the South Warwickshire Local Plan into the development of the wider West Midlands region. This is because the duration of the Local Plan is significantly long and within this period currently unforseeable factors may influence the movement of employment and people across the region.

Stratford-upon-Avon Town Transport Group (TTG) Response to the South Warwickshire Local Plan: Issues and Options Consultation, January 2023 This submission is provided by the Stratford-upon-Avon Town Transport Group (TTG)i , in response to the South Warwickshire Local Plan: Issues and Options Consultation, January 2023. We note that the consultation includes 106 questions, and in this context are concerned that key messages maybe lost, and have therefore prepared this stand-alone response. This response considers 3 areas: 1. The Vision and Strategic Objectives 2. The Development of the Plan 3. Stratford-upon-Avon 2. The Development of the Plan The TTG consider there are three fundamental factors which should steer the Local Plan, and be taken into account in defining the locations of any new settlements or expansions of existing settlements. 1. Homes and Jobs – the location of housing in relation to employment. 2. Infrastructure Planning to unlock housing development, and not vice-versa. 3. A deliverable Transport Plan based around interconnectivity and complete journeys from origin to destination. Homes and Jobs The concept of the 20 minute neighbourhood, in terms of providing for residents basic local needs and hence reducing the need to travel and enhancing wellbeing is supported; as is the use of the concept as a criteria in comparing options.However, the number of jobs provided within a 20 minute neighbourhood will be significantly lower than will be required to support any new or expanded settlement, which are likely to be in the range of 1 to 2 jobs per home.It is suggested that an economic study, which looks at the spatial locations of these new and existing jobs, both within and outside the area of the Plan, is required as a major input to the analysis of locations for new housing. In the view of the TTG, this would be a key factor in assessing transport, working towards a cost-effective solution for families, and achieving net zero. Infrastructure Planning & Delivery The plan identifies that the infrastructure required for a new or expanded settlement takes several forms. It is accepted that some of these are not viable at the early stages of a development, however they should be planned at the outset. Key infrastructure such as transport should be financed and delivered in advance of the development to unlock the building of homes, as is done elsewhere in the UK. It is essential that both WCC as the transport authority and SDC/WDC commit to delivering the transport infrastructure at the outset, to avoid the issues that have plagued the Long Marston Garden Village, and to provide a transport framework to support the Local Plan through to 2050. The Plan and Sustainability Appraisal use the term Mitigate as a solution to lessen the impact of particular effects. In a number of cases, this term seems to have been used without a solution in mind, and in the TTG’s view, in several cases mitigation would not be possible, or would be economically unviable. In the TTG’s view, the focus should be on good planning including transport planning, which would deliver a comprehensive Local Plan, and therefore not need mitigation. The TTG’s view is that a new settlement has the potential to deliver the majority of the housing needs, with the minimum effect on the environment, and without detrimental effect on the character of existing settlements, providing the settlement is of sufficient size to attract investment, and that transport infrastructure is planned and installed at the outset. In order to achieve this it is suggested that a form of Development Corporation incorporating all tiers of local government and public sector investors, would deliver the best outcome. 3. Stratford-upon-Avon Regardless of the option considered, the outcome for Stratford is virtually identical in all cases. So from Stratford's perspective, there are no options in the Options Report. The TTG consider this a major flaw. The Plan does not address the outcomes it would deliver and how it would affect people and their quality of life. Specifically, would it mean more congestion, more car parks, less likelihood of pedestrianised and quiet areas, etc., etc. Would it mean that Stratford loses some of the character which makes it distinct? As described earlier, planning and transport, housing and employment, need to be agreed together, and should underpin the plan. Stratford-upon-Avon will inevitably attract commuters, and this will be compounded if Birmingham and Coventry overspill is required to be taken up. The completion of HS2, and the government levelling-up initiative will further increase the numbers relocating to jobs in Birmingham who may find Stratford-upon-Avon a desirable location to live. Has the plan taken into account the analysis of jobs and likely markets for new housing that have been done in this regard? The previous paragraph is a prime example of the issue raised earlier in terms of Homes and Jobs, and deserves a proper analysis of how “where people live and work” will impact South Warwickshire during the life of the Plan. This would appear to be a vital input to deciding whether to discourage development around Stratford on “net zero” grounds, or to plan for good commuter infrastructure (eg: improved rail as well as road). The supporting Sustainability Appraisal does not appear to consider where people will travel to, the volume of travellers, and the potential / viability of amendments to transport infrastructure required. Furthermore, it scores potential development sites based on issues such as distance from existing bus stops, without consideration of how easy it would be to change a bus route between now and 2050, and uses the word mitigation liberally, without consideration of the cost or practicality of transport infrastructure required in and around Stratford-upon-Avon. A specific example of where major infrastructure needs to be planned and financed, before locations can be unlocked for development, is land south of the River Avon. This applies both to the new settlement shown in all options and to any development on the edge of Stratford south of the river. The Clopton Bridge is now at capacity and studies have shown that it would not be able to accommodate the associated increase in traffic. Land in these areas should not be earmarked for development, even at a strategic level, without first addressing the viability and impact on residents of associated infrastructure which is likely to include extensive civil engineering.

Option S2-C: Intensification 20. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Richborough Estates 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. 21. 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.

Option S2-C: Intensification 18. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Richborough Estates 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. 19. 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.