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

9. Land North of Milcote Road (West), Welford-on-Avon 9.1. Rainier Developments is promoting land north of Milcote Road (West), Welford-on-Avon for residential development. 9.2. The land is currently a single agricultural field. The eastern and western boundaries are defined by existing hedgerows, the northern boundary by a tree belt and the southern boundary by Milcote Road. Immediately adjacent to the site to the west is a recent residential development (known as Milcote Close). There is also a large residential dwelling to the south of Milcote Road, opposite the Site. 9.3. The site is not in the Green Belt. The site is located within Flood Zone 1, land at least risk of flooding, and does not include any significant areas of surface water flood risk. The Site is not located in close proximity to the Welford-on-Avon Conservation Area or any designated heritage assets. 9.4. The site was assessed as part of the SHLAA 2021 Update (Welford-on-Avon, Site 9A). In terms of suitability, it concluded that the site was technically suitable for development but commented that in terms of environmental suitability that “Landscape Impact. Impact on settlement character. High quality agricultural land.” It also noted under scope for mitigation that the site forms part of a strategic gap between Welford and Weston in the made Neighbourhood Plan. 9.5. The technical suitability of the site is not disputed. In terms of landscape impact and impact on settlement character these are matters which could be resolved by a carefully considered, landscape-led design. The development of Milcote Close means that this site now directly adjoins the built-up area of Welford. Development of the site would not extend the settlement pattern beyond the eastern edge as established by Chapel Street and Pool Close to the north and Milcote Road to the south. 9.6. It is acknowledged that the site is included within strategic gap as defined by the Neighbourhood Plan. However, the site forms a relatively small part of this gap. The Site is well separated from Weston on Avon and is significantly smaller than the site of the proposed Gladman scheme referred to in the supporting text to Neighbourhood Plan policy HE6. This scheme included the adjacent, larger field and would have extended further east, beyond the existing settlement pattern. This proposal was also for a significantly larger number of dwellings than this Site could accommodate. This Site would be more akin to the development of the adjacent Milcote Close than the Gladman proposal and the larger agricultural field to the east does not form part of this Site. This would also reduce the amount of agricultural land which would be developed. 9.7. The accompanying Illustrative Masterplan (enclosed at Appendix 4) shows how the site could be developed, with built development shown towards the western boundary (adjacent to Milcote Close), with looser development across the site and a landscape buffer along the eastern boundary. The area adjacent to the northern boundary is also shown as a landscaped area which could accommodate sustainable drainage and an on-site play area. The Masterplan shows how the existing boundary planting could be retained and enhanced. The Masterplan shows how the site would read as a rounding off of the existing settlement and could be developed to form an attractive settlement edge to Welford-on-Avon. 9.8. The South Warwickshire Plan presents the opportunity to review all designations and ensure they remain appropriate. Welford-on-Avon is a sustainable settlement with a range of local services and facilities including a primary school, post office & convenience store, pubs and allotments. There is also access to public transports with bus stops providing a service to Stratford-upon-Avon. It is clear that Welford-on-Avon is a sustainable location and should be allocated appropriate growth as part of the South Warwickshire Local Plan to secure the continued viability and vitality of the settlement and deliver development to meet housing needs, including affordable housing. Land north of Milcote Road is suitable to deliver residential development, including affordable housing, and should be included as an allocation. 9.9. At this stage, the Sustainability Appraisal (SA) does not consider settlements outside of those identified as Broad Locations, Small Settlements and New Settlement Locations. Whilst it is acknowledged that the Plan is at an early stage and the SA will evolve as the Plan progresses, it should assess the settlements identified within the ‘dispersal’ option to ensure that reasonable alternatives have been properly considered. Summary 9.10. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.11. The site is not subject to any designations or constraints that would preclude the development. The Illustrative Masterplan demonstrates that an appropriate design could be achieved on site to deliver a sensitively designed scheme which responds to the site’s location. 9.12. The site is well located adjacent to the existing built edge of Welford-on-Avon and a sensitively designed scheme would respond to and reflect the settlement pattern established by existing development to the north. 9.13. The site is not subject to any statutory nature or heritage designations. The Site is entirely within Flood Zone 1 which represents the lowest risk of flooding. The Site could deliver sustainable drainage systems (SuDS) as part of any development. 9.14. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.15. Rainier have a land interest in the Site and are promoting the site for residential development. 9.16. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.17. Rainier’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation and previous representations throughout the preparation of the South Warwickshire Local Plan. 9.18. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.19. Rainier have a land interest in this Site and are actively promoting the Site for residential development. The site is immediately available and could deliver housing in the early part of the Plan period.

I am writing to you in regard to the current South Warwickshire Local Plan and my land ownership that forms part of the Broad Location of Royal Leamington Spa East. Attached to this letter is a plan showing my full landownership and its coverage by the Broad Location. Attached with this letter are specific responses to the consultation questions. I welcome the publication of the South Warwickshire Issues and Options consultation document and associated technical evidence. It responds positively to the need to plan for sustainable development; meet the challenge of climate change; and identify land to meet local needs including for housing and jobs. I support the identification of Royal Leamington Spa as a location for growth and the inclusion of the Broad Location at Royal Leamington Spa East. Royal Leamington Spa is a main settlement that provides services and facilities for people to meet their regular day to day needs within a reasonable walking distance of their homes as well as having access to transport options that will enable them to travel sustainably. Growth at this settlement will meet the 20-minute neighbourhood principle and ensure that a sustainable pattern of development is delivered. I consider that the Broad Location of Royal Leamington Spa East can deliver a sustainable urban extension of circa 2000 homes. This sustainable urban extension presents the opportunity to deliver new infrastructure for the growing community, provide access to existing facilities and services and potential, where evidenced, for improved facilities for the existing communities of Lillington and Cubbington. The Broad Location also provides a unique opportunity to deliver an extension to the Newbold Comyn and create access to this wonderful facility for the communities at Cubbington and Lillington as well as those living in the new sustainable urban extension. Better access can be provided to the wider countryside including the national cycle network. Through considerate design a beautiful place can be created that has the potential to deliver benefits for people and nature. I also believe that there are exceptional circumstances to justify changes to the Green Belt boundaries and to allocate land at Royal Leamington Spa East for residential development of circa 2000 homes. The circumstances include being the most sustainable option for growth, ensuring that the Council has sufficient land to meet its housing needs, and extending leisure and recreation facilities at Newbold Comyn and create new pedestrian and cycle connections for the benefit of the wider community and to promote sustainable travel. To help demonstrate the availability and achievability of residential development at this Broad Location the landowners including myself, King Henry VIII Charity, and Sir Thomas White's Charity are in discussions on the promotion of land within the Broad Location for residential development. I look forward to working with the Council to realise the potential of this Broad Location and secure the potential significant social, economic and environmental benefits that could be achieved through residential development.

I am a resident of Barford and specifically object to: A. Employment/Industrial/Commercial uses south-east of Longbridge Junction 15 which is the land south of the M40 and to the north of Barford. This area should not be utilised as it destroys the rural nature of the surroundings. B. Mixed uses south of and adjacent to Westham Lane in Barford. The area west of Westham Lane should not be developed as the A429 is extremely busy and dangerous at Westham Lane junction especially when turning into Westham Lane heading south. WCC already intends to enforce the development of a quarry with huge increases in HGV traffic. C. Employment/Industrial/Commercial uses on land between the A425 Banbury Road and the M40 bounded to the north-east by Barford Woods. This area should retain its buffer zone status. D. Mixed uses south-west of the A425 between Europa Way and M40 junction 13. This site should be retained for agricultural usage only. The objective shall be to effect a well designed and beautiful south Warwickshire, the gateway to the Cotswolds! Urban sprawl and the destruction of the rural nature should be a priority.

I strongly object to the Greenbelt being used. The Greenbelt is important for so many reasons high quality agricultural land, footpaths used by hundreds of residents to improve their mental and physical health. I don’t want sprawling development towards Kenilworth leaving no discernible difference between the two towns. Stop this now. A very unhappy resident who has fought this battle just too many times. Listen to your residents the people who you serve and should have our best interests in mind.

We would like to express our concern over any development of the Green Belt north of Leamington and the potential threat that this poses for our allotment site. Any development of the Green Belt sets a dangerous precedent that could conceivably result in building & housing development on or around our site in the future. Established in 1920, we're a 150+ member Society with our members tending 165 plots. Our membership represents a broad cross-section of society, young & old, with many plots worked by not only individual members but their partners, their children, their grand children. The benefits of allotment gardening cannot, in our view, be underestimated in terms of physical & mental health well-being. Environmental benefits are also vitally important both in terms of wildlife but also the growing of local produce with virtually no carbon footprint. The five stated purposes of Green Belt land are to: 1) Check the unrestricted sprawl of large built-up areas 2) Prevent neighbouring towns merging into one another 3) Assist in safeguarding the countryside from encroachment 4) Preserve the setting and special character of historic towns 5) Assist in urban regeneration, by encouraging the recycling of derelict and other urban land. In our view the consultation document completely fails to consider adequately these core principles and ignores the legitimate function served by the Green Belt. We would strongly suggest that the Council explore alternative options for housing development rather than destroying this part of south Warwickshire.

As an allotment holder on the Binswood Ex-Servicemen’s Allotment Society and a local resident, I write to express my alarm that all five spatial growth options of the above involve some development in the Green Belt and refer to the Green Belt to the North of Leamington as an area of ‘significant urban extension’. I am concerned that the assessments of the two proposed development sites state that the locations would be “unlikely to lead to coalescence of settlements”. However any development would join Old Milverton and Blackdown to Leamington Spa and bring Leamington Spa close to the southern suburbs of Kenilworth. This all appears to ignore the legitimate function served by the Green Belt, contrary to very recent Government announcements, the 2015 green belt review and the detailed 2017 response by the Planning Inspector. The Secretary of State’s letter in December which made a “brownfield first” pledge and has recently made it clear in a letter from the Secretary of State for Levelling Up, Housing and Communities, that local planning authorities such as Warwick District Council are not expected to review the Green Belt to deliver housing and I believe this should be the basis on which Warwick District Council responds to unmet housing need in other neighbouring authorities. The Planning Inspector’s 2017 response to the current Warwick District Local Plan which states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth”. It also points out that: “Development to the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have significant adverse impact on the openness of the Green Belt and the character and appearance of the area”. Development within the Green Belt to the north of Leamington Spa would substantially reduce the land that separates Kenilworth from Leamington Spa. It is my opinion that the Green Belt around the North of Leamington fulfils the five stated purposes of Green Belt land are to: 1) Check the unrestricted sprawl of large built-up areas 2) Prevent neighbouring towns merging into one another 3) Assist in safeguarding the countryside from encroachment 4) Preserve the setting and special character of historic towns 5) Assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The Green Belt around the North of Leamington is highly valued open space and contributes greatly to the physical and mental health of allotment holders and local residents alike, this was especially true during the recent lockdowns and we would all suffer immeasurably through a loss of this amenity which also provides significant habitat for wildlife. It is also high quality agricultural land; recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The Government is clear that it seeks to protect such land from non-agricultural development. The National Planning Policy Framework states, “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality”. I urge you to halt the development of the Plan until it has been reviewed further to fall into line with Government guidance and the standing Planning Officer recommendations.

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the Green Belt. Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is, to quote the letter from Michael Gove MP “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The Green Belt around North Leamington is recognised as a genuine constraint to development. Q-S5.2 - New Settlements: It is wholly unacceptable to consider the development of a new settlement within Green Belt land. There are no 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 time and effort is to be invested in a new settlement this should only be looking at non-green belt land thus avoiding an un-winnable battle over exceptional circumstances. Q-S5.3 – Rail Corridors. The prioritisation of rail corridors may offer a sensible option for development. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station but given the travel time this can only be justified in non-green belt areas otherwise it will again fail the exceptional circumstance test because there is ample geographical options to achieve this outside of the Green Belt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Green Belt. 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. The Climate Emergency is not a justification to develop on Green Belt land, in fact it is the opposite. This appears to be a weak ill-considered argument as there are other ways of mitigating against the climate emergency without developing on prime agricultural land in the Green Belt. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in Green Belt areas. The plan should not allow for more small-scale growth developments to come forward in Green Belt areas. Q-S10 – Any other comments: I am specifically opposed to development of land to the North Leamington Greenbelt and areas such as Old Milverton, Weston under Wetherley and other similar small Green Belt villages due to the impact on the rural character of the area and the implicit urban sprawl. The Planning Inspector’s 2017 response to the current Warwick District Local Plan states that there is a need “to maintain the separate identity of surrounding villages and avoid significant reductions in the gap to Kenilworth” (p18, para 91). It also points out that: “Development to the land in question would involve a substantial expansion of the built-up area into currently open countryside to the north of Leamington Spa. It would have significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p34, para 201). The construction of HS2 has made the existing Green Belt even more valuable and the Inspector’s wise comments are indeed more relevant than they were in 2017. The Climate Emergency is not a justification to develop on Green Belt 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. The statistics in Chapter 4, issue S6 are misleading. The number of respondents (561 responses) to the first consultation was exceptionally small and can in no way be considered representative of the population area. Most people felt the previous consultation was aimed at site owners and did not respond, which explains the low response rate. This issue should not have been included within the consultation without the option to comment. Your statistics are entirely misleading stating that 54% of respondents to the first consultation, Scoping and Call for Sites, supported “exploration for growth opportunities” in the Green Belt. The planning team appear to be using this as one of the justifications for reviewing Green Belt boundaries. However, 35% of respondents to that consultation were developers and 10% were businesses or landowners, suggesting that only a small proportion of other respondents were in favour. The heavy weighting towards groups with vested interests should be treated with caution and certainly not used as justification. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). The letter from the Secretary of State Secretary of State in December does in itself justify halting the current work on the South Warwickshire Local Plan until the updated NPPF is finalised. This would enable the South Warwickshire Local Plan to be realigned with the Government’s clear intention for planning authorities to have more power to resist identifying Green Belt land for development if the only solution for meeting assessed housing need would be to build on Green Belt land. I am also is concerned that the assessments of the two proposed development sites are in the 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both assessments state that the locations would be “unlikely to lead to coalescence of settlements”. However, any development would join Old Milverton and Blackdown to Leamington Spa and bring Leamington Spa close to the southern suburbs of Kenilworth. The Green Belt has a major purpose in stemming the loss of open space between the West Midlands, a major urban conurbation, and neighbouring towns and villages. The proposed developments would significantly reduce that green corridor and have a detrimental impact. The officers have done considerable work on the Issues and Options consultation of the South Warwickshire Local Plan, but sadly the process is flawed because all five spatial growth options involve some development in the Green Belt. It is even more unfortunate that all of them refer to the Green Belt to the North of Leamington as an area of ‘significant urban extension’. This all appears to ignore the legitimate function served by the Green Belt, and is contrary to very recent Government announcements, the 2015 green belt review and the detailed 2017 response by the Planning Inspector

Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 3.12. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.13. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.14. Growth at existing settlements across the Joint Plan area should form part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. 3.15. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.16. In order to develop the most sustainable pattern of development, growth at existing settlements should be in sustainable locations. It is important that appropriate levels of growth are apportioned to existing settlements in order to maintain the vitality and viability of settlements, support new and existing infrastructure requirements and provide an appropriate mix of housing for the area. 3.17. Stratford-upon-Avon, identified as the Main Town is a sustainable location for development and development at the Site would allow for a sustainable development close to existing services and public transport. 3.18. As set out in the Sustainability Appraisal, the site is within the Broad Location ‘Stratford Northeast’ which the SA shows is least constrained in terms of environmental receptors (see Table at 4.15.1). 3.19. It is clear that this Site (Call for Sites ref: 38) is located in an entirely sustainable location and should be positively considered as a location for growth. Issues S6: A Review of Green Belt boundaries 3.21. The Issues and Options consultation document does not set out any specific question on Green Belt matters, but these representations support a review of the Green Belt boundary as part of the Plan making process. 3.22. As set out in the NPPF para 136, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of Local Plans. Moreover, strategic policies should establish the need for changes to Green Belt, and where proposed, the amended boundaries should be able to endure in the long term, i.e. Green Belt boundaries will not need to be altered at the end of the plan period. 3.23. NPPF para 137 requires exceptional circumstances to include evidence of the examination of all other reasonable options for meeting an identified need for development. Importantly, in reviewing Green Belt boundaries sustainable patterns of development should be taken into account. 3.24. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and review growth options, where the most sustainable form of development is likely to be around existing settlements, it is therefore imperative that the Local Plan evidence base includes a Green Belt review. The Councils’ recognition of this in relation to a number of the proposed growth options is supported. 3.25. If a Green Belt boundary review is not undertaken, development will need to ‘jump the Green Belt’ which would result in an isolated pattern of development. Q-S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 3.26. It is noted that the Issues & Options document has reduced the previous seven growth options presented in the Scoping Consultation to five options as outlined above through refining and combining options, including Option 2 sustainable travel (combination of rail and bus corridor) and Option 3 economy (combination of socio-economic and enterprise hub options). In this consultation document, Option 4 sustainable travel and economy effectively combines Options 2 and 3. It is clear from this process that the growth option to be pursued will represent a combination of all five options outlined above. 3.27. The options now presented in the Issues and Options, apart from Option 5: Dispersed, perform broadly similarly to each other in the SA (Table 7.1) suggesting not one option may have significantly more or less impact than any of the others when considered against the SA Framework. At this stage, the SA has not considered any mitigation or site-specific options for growth within settlements identified within the ‘dispersed’ option (5). There could be significant variance in how each settlement and individual sites would perform against the SA objectives. All of the growth options could deliver sustainable development and a combination of all options will be the most appropriate option for the development of the Plan going forward. 3.28. By necessity, the strategy will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66 year supply of housing. Land from other sources will therefore be required and it is important that all options are considered in taking the Plan forward. 3.29. Combining sustainable travel (including rail) and economy will naturally direct most growth to the larger, more sustainable settlements. However, it is important that appropriate, proportionate growth is directed to smaller settlements in order to support the continued viability and vitality of these settlements going forward. This would include supporting or enhancing sustainable travel options at these locations. This needs to be positively planned for as part of the South Warwickshire Local Plan and as such an element of dispersal should form part of the final growth option. This will require a careful consideration of all of the options, including growth at existing main settlements, growth at smaller existing settlements, proximity to services and jobs, availability of infrastructure or opportunities for infrastructure delivery and a Green Belt boundary review to ensure development is not isolated beyond the defined Green Belt boundaries. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Q-S8.2 For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 3.30. The supporting text for this question confirms that the aim of this approach would be to allow for development within or adjacent to existing settlements. This provides greater scope of these settlements to accommodate growth than the current infill only approach. The proposed approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. 3.31. An across the board threshold limit of 10 dwellings is not supported. The amount of development different settlements can accommodate will vary significantly depending on various factors, such as existing services and facilities, local need for housing and the suitability of the proposed site to accommodate a certain level of development. 3.32. In addition, developments of 10 or fewer dwellings are exempt from affordable housing. Even where a lower threshold is set, developments of this scale generally result in a commuted sum towards affordable housing elsewhere. This is due to a variety of factors, including that registered providers often will not take on a small number of dwellings in one location. It is clearly preferable to have affordable housing delivered on site wherever possible to meet local needs. Setting a more flexible threshold that would allow for a higher level of development where appropriate would support greater on-site affordable housing provision. Q-S9: Please select the option which is most appropriate for South Warwickshire 3.33. The South Warwickshire Local Plan provides the opportunity to review all settlement boundaries and ensure they will be fit for purpose across the plan period. Saving all existing settlement boundaries is unlikely to be effective in positively planning for plan-led growth across the plan period. This should apply all settlements as part of the exercise will be to assess which settlements which would benefit from a defined boundary. 3.34. To be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. 3.35. In addition, settlement boundaries will need to be reviewed and amended to take account of new allocations. 3.36. For example, the Green Belt boundary and development boundary for Ettington should be reviewed which would allow for the inclusion of this Site (Call for Sites ref: 38) within the development boundary to deliver sustainable residential growth.

9. Land South of Banbury Road, Ettington 9.1. Rainier Developments is promoting land south of Banbury Road, Ettington for residential development, inclusive of on-site green infrastructure. 9.2. The Site comprises an agricultural field immediately to the south of Banbury Road. Land to the north of Banbury Road (opposite the site) is comprised of residential development, as is the land immediately adjoining to the site to the north-west. The Site is logically located to round-off the village and would not disrupt the settlement pattern as it would not extend development beyond the existing development line to the north of Banbury Road. 9.3. The site is not in the Green Belt. The site is entirely within Flood Zone 1 with a small area of surface water flood risk, close to Banbury Road. This could be addressed by way of a suitable sustainable drainage scheme. The closest designated heritage asset is 67 and 69 Banbury Road which is a Grade II Listed Building. This is located north of the site and separated by existing built development. 9.4. The northern part of the site (immediately adjoining Banbury Road) is allocated in the Ettington and Fulready Neighbourhood Plan (Made December 2018) as a reserve allocation for around 8 dwellings (please see policy extract enclosed at Appendix 3). The remainder of this site is identified as a Self-Build and Custom Housing Allocation in the Stratford-on-Avon Site Allocation Plan (SAP) Preferred Options (July 2022) which identifies the site as having capacity for approximately 16 dwellings (please see policy extract and plan enclosed at Appendix 4). This is an approximate figure and the Illustrative Masterplan (please see Appendix 5) demonstrates that the Site could accommodate circa 24 dwellings. 9.5. It is clear from the existing and proposed allocations that the site is considered to be entirely suitable to accommodate residential development and this should be acknowledged through a suitable allocation in the South Warwickshire Plan. 9.6. As discussed in preceding sections, Stratford-on-Avon District Council have undertaken work to identify sites to deliver self-build and custom housing. This is considered to be a better approach compared to allocating a small percentage of plots on strategic sites which are unlikely to be aligned with self or custom builders aspirations for more unique properties and design. The provision of serviced plots on smaller sites will better fulfil this housing need. It is therefore suggested that the self-build and custom housing allocations from the SAP Preferred Options are carried forward into the South Warwickshire Plan and a similar approach is taken to identify suitable sites in Warwick District. 9.7. At this stage, the Sustainability Appraisal (SA) includes two references to self and custom build housing, both in the context of meeting overall housing needs (SA Objective 9). It is recognised that this is an early stage of the plan-making process and that the SA will evolve as the Plan progresses. Going forward, the SA should consider the reasonable alternatives for meeting self and custom build housing need, including making specific site allocations. This should include consideration of sites for allocation. 9.8. It is clear that this Site is unconstrained, has been identified in the SHLAA as potentially deliverable and is well-placed within Ettington to accommodate development. This is reflected by the allocations in the Neighbourhood Plan and the SAP Preferred Options. This should be carried forward to the South Warwickshire Plan and the Site should be allocated. Summary 9.9. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.10. The Illustrative Masterplan shows how the site could accommodate circa 24 dwellings with an access from Banbury Road. A connection to the playing fields to the south would be feasible if this is something the owners of the playing fields considered this to be appropriate. 9.11. The site benefits from a sustainable location in Ettington is well placed to meet the housing needs of the area. The site is well-placed to ensure easy access to a range of services and facilities including the playing fields, community centre and primary school. 9.12. The site is not subject to any statutory nature or heritage designations. The site is entirely within Flood Zone 1 which represents the lowest risk of flooding. The Site could deliver sustainable drainage systems (SuDS) as part of any development. 9.13. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.14. Rainier have a land interest in the Site and are promoting the site for residential development. 9.15. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.16. Rainier’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation and previous representations throughout the preparation of the South Warwickshire Local Plan. 9.17. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.18. Rainier have a land interest in this Site and are actively promoting the Site for residential development. The site is immediately available and could deliver housing in the early part of the Plan period.

This is a representation from the Liberal Democrat Group of Stratford District councillors. It is noted that consultation is for a high level, long term plan and such the detail effect of policies will take time to emerge. This response does not preclude individual members and residents making representation that relate to local areas.

Q-S2: It would seem appropraite to consider intensification, but this will be limited to those areas where adequate mitigation can be provided. Option S2a seems the most appropriate approach. Q-S4.1: Growth of existing settlements should form part of the identification of sustainable and deliverable growth but a general policy on supporting growth of existing settlements could be problematic. It is recognised that growth in some areas could prove beneficial if it brings improvements to services. However growing existing settlements should only be considered where impact can be adequately mitigated. Growth in some smaller villages could help with the delivery of affordable homes encouraging younger families to move to the area. However, these small villages are often without education or health provision and public transport can be patchy. Large scale growth within one location can provide an opportunity to deliver new social infrastructure such as schools, health provision, green space etc. and active travel options can be planned in. Although this can be challenging, especially in those situations where the proposed growth area is made up of a variety of land parcels under separate ownership, we do believe there are examples of good practice within Warwickshire that could help inform the South Warwickshire Local Plan. Q-S5.2: We believe that the delivery of new settlements will provide an opportunity to develop sustainable neighbourhoods. The settlements to be of sufficient size that they will deliver social infrastructure such as education and health facilities as well as available green space and employment provision. Q-S8.1: Although on the face of it this could be a sensible way forward, this would need to be carefully considered and monitored to ensure this didn’t simply become a mechanism for generic dispersed growth and the difficulties this can cause. Thresholds would need to be agreed by the Local Community and reflected in the corresponding Neighbourhood Development Plans. Q-S8.2: The threshold size and how this will be delivered could be different for each community, but it should align with the corresponding neighbourhood plan. Q-S9: It would seem appropriate to reconsider this at the next stage of consultation.

We are writing with regard to the proposed development areas suggested recently surrounding Wootton Wawen. While we believe development is necessary, there are certain sites which we feel are more suitable than others suggested within the local SWLP, as per the map below. The SWLP rightly identifies that "mitigating biodiversity loss" is important, as well as protecting historical sites. It is our view that much of the above area identified in the brown outline is in contravention of these aims, but there is one site which has potential to be sensitively and sustainably developed, which is the area to the rear of the school, where "sewage works" is currently marked on the above map. This is away from the monument mentioned below, and has the possibility to be served by more public transport options than the sites off Stratford Road. Our reasons for objecting to the development of the currently agricultural land either side of Stratford Road are below. 1. Impact on the sites of historical importance. St Peter's Church or the Saxon Sanctuary, has incredible history and sits amid green space surrounded by a traditional village landscape. Engulfing this site into an area surrounded by new developments would have an intractable effect on this monument. Sites like these ought to be protected, not absorbed into a housing sprawl. 2. Safety - the A3400 is a road which already suffers from a poor road safety record, with multiple serious incidents reported in the last 5 years. The public transport system is poor, with the rail station being the only useful mode of transport as the bus service is minimal. Increasing development, junctions and therefore traffic in areas already prone to accidents is against the Sustainable Transport option in the local plan. 3. Ecological and climate change reasons - redevelopment of existing sites where there is not current agriculture is far more sustainable than using field land for development. The potential loss of biodiversity, wildlife, and disruption of ecosystems is considerable and substantial if this land is to be used for housing. 4. Sustainable transport - The local school is below capacity, so development which attracts young families adjacent to the school to encourage sustainable transport to school would be a sensible option. Families located further away would likely still use cars to drop children to school, as parents would be very unlikely to work within walking distance, and adding a longer walk to school and then a return home to commute would not be something many families would consider. It is my experience that most families in our area have two working parents, or are single parent families with a working parent, and will drop children to school on their way to work unless they live very close to school. 5. It is our view that sensitive development in the relatively tucked away area behind Wootton Wawen School and adjacent to current housing would have the least impact on the character of the village, protect most of the green belt, and deliver the best compromise between economic growth and protection of the climate and heritage of our beautiful village.

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt.

Overall. I do not believe that Kingswood should be identified as a ‘growth village’ for the following reasons 1. The local road network is TOTALLY inappropriate to accommodate further significant housing development (see further comments below); 2. Significant development is likely to impact on the rural character of the area, including along the canal corridor; 3. Although served by rail services (with very little parking), these services are VERY limited with no alternative bus services available when unreliable; 4. From my local experience, current patterns of movement and travel for shopping, leisure, secondary school education and social contacts, particularly to Knowle and Dorridge, often inevitably involves car travel on narrow roads with limited footpaths 5. Overall, compared to larger settlements with a range of higher level services, Kingswood is NOT a sustainable location for further significant development given the limited scale of local services and the inevitable need for full use of the car. I am particularly concerned about existing traffic on the following local roads which could worsen significantly with large scale development. 1. Station Road – walking children to school from Kingswood Close is very problematic given the lack of footpath at this end of the road. The alternative of using and parking a car to deliver children can also be very problematic at peak times; 2. Rising Lane – the speed of traffic and the lack of footpath makes this very hazardous when people are walking ....sometimes with pushchairs! 3. Chessetts Wood Road – this narrow road is sometimes incredibly hazardous particularly at night. There are no edge markings and in places deep ruts along the edges. At the far end, narrow bends often have parked vehicles and there is a narrow bridge over a culvert. The greater level of traffic on this road, the higher the level of potential danger. 4. Chessetts Wood Road – the road is very much used as a leisure/recreational route on almost all days but particularly at weekends with cyclists, walkers, horse riders and runners/joggers. Consideration should therefore be given to designating this road as a leisure route with the speed village limit lowered to 30...or even 20....mph. 5. Given these concerns, I believe that, as with existing Local Plan, any development in Kingswood should therefore be limited in scale and be located at the Old Warwick Road end of the village.

Argument 1. The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Argument 2. The Green Belt around North Leamington is a valued open space. In surveys residents say that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health. It is easily accessible on foot from North Leamington so many people can access the public rights of way across the fields. Use of these footpaths increased markedly during lockdown and these high levels of use continue today. The agricultural land continues to provide rural employment and undergo diversification of farming techniques. Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever. Argument 3. The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. Recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The land making up these sites is, therefore, considered to be a scarce resource of high value for sustainable food production. The Government seeks to protect against the loss of such land from non-agricultural development. The National Planning Policy Framework is clear that “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality”; a policy which will continue to grow in significance as the increasing cost of imported wheat and grain drives up domestic food production needs. Argument 4. The proposals would lead to a merging of the boundaries of Kenilworth and Leamington. Developing the North Leamington Green Belt would significantly reduce the belt of land that separates Kenilworth from Leamington, particularly in view of the Thickthorn housing development now underway and other recent housing and commercial developments in the area. The proximity of HS2 developments in neighbouring parishes is also strongly felt. Despite this, numerous other sites along the A452 have been put forward in the Call for Sites. Once land is removed from the Green Belt for development this cannot be undone and a precedent is set which makes it easier for adjoining swathes of land to be built on. Building more new houses on the outskirts of Leamington will exacerbate the current high levels of traffic congestion which has come with the new housing developments south of the town. The original layout of the town and the subsequent development in the 19th and 20th centuries precludes the construction of major new cross town access routes. The joint Green Belt study of 2015 highlights the important contribution to preventing the merging of Leamington, Kenilworth and Coventry that this piece of the countryside (Broad Area 3) makes by preventing urban sprawl, safeguarding the countryside and preserving the special character of these historic towns. Argument 5. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. Argument 6. It is not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (See letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints” (see letter above). The utility of the Green Belt around North Leamington is a genuine constraint on development. Argument 7. It skews development away from affordable housing in the areas where people work. The Government has also made a “brownfield first” pledge (see letter above) which should inform the way that the District Councils respond to unmet housing need in other authorities. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit. Argument 8. The process is flawed because all five options presume Green Belt development without acknowledging the significant constraints involved. The Issues and Options consultation puts forward five “spatial growth options”. All of these would involve development of some areas of Warwickshire’s Green Belt, and all of them suggest North Leamington Green Belt as an area of ‘significant urban extension’. This is in line with the outcomes from a series of spatial growth workshops which revealed a preference to promote development at scale within the Green Belt. However the premise of these workshops is grossly flawed. The proposition that Green Belt serves no legitimate function and can be ‘switched off’ as an academic exercise flies in the face of the significant contributions that Warwick District Council and Stratford District Council have themselves noted that Green Belt designation makes. The Green Belt puts major restrictions – for good reason – on what can be built where. The spatial growth workshops did explore growth options where Green Belt development was not permitted. However none of these feature in the current five spatial growth options. This is contrary to recent Government announcements, the 2015 greenbelt review and the 2017 response by the Planning Inspector. Argument 9. The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. I think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development.

Issue S6: A review of Green Belt boundaries To fully consider all options, the spatial growth options are presented with Green Belt policy “off”. Therefore, all five refined options include locations within the Green Belt. The Issues and Options confirms that a decision “on whether to take land out of the Green Belt are interlinked with the selection of a growth option, and the balance of Green Belt and non-Green Belt locations varies between growth options”. A large area of Stratford and Warwick is designated as Green Belt. This includes the majority of the area’s railway stations with several lines running through the area covered by Green Belt. The Issues and Options document states acknowledges that “the location and spread of the Green Belt in South Warwickshire may mean that limiting growth to locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option as it pushes development away from areas that are well connected with good infrastructure and better access to facilities and services towards areas with more limited infrastructure and where further travel would be necessitated.” The Issues and Options document states that the responses to the previous consultation confirmed that 54% of respondents supported the exploration of growth opportunities in the Green Belt. We consider that a Green Belt review is necessary. In the context of the proposed Plan Period up to 2050, it seems reasonable to assess all sites, both Green Belt and non-Green Belt. It is considered that the South Warwickshire Plan should consider growth opportunities in the Green Belt where they would offer sustainable development (for example railway connections)and agree with the Issues and Options document that locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option We believe that a Green Belt Review should form part of the evidence base, to ensure that development is not excluded in sustainable locations.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 3.12. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.13. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.14. Growth at existing settlements across the Joint Plan area should form part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. 3.15. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.16. In order to develop the most sustainable pattern of development, growth at existing settlements should be in sustainable locations. It is important that appropriate levels of growth are apportioned to existing settlements in order to maintain the vitality and viability of settlements, support new and existing infrastructure requirements and provide an appropriate mix of housing for the area. 3.17. Harbury is identified within Option 5 however it benefits from a range of local services and facilities and would contribute towards achieving the Council’s aspiration for 20 minute neighbourhoods. The SA should assess Harbury and proposed development options for the settlement, including this Site. 3.18. This Site (Call for Sites ref: 459) is located in a sustainable location and should be positively considered as a location for growth. Issues S6: A Review of Green Belt boundaries 3.20. The Issues and Options consultation document does not set out any specific question on Green Belt matters, but these representations support a review of the Green Belt boundary as part of the Plan making process. 3.21. As set out in the NPPF para 136, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of Local Plans. Moreover, strategic policies should establish the need for changes to Green Belt, and where proposed, the amended boundaries should be able to endure in the long term, i.e. Green Belt boundaries will not need to be altered at the end of the plan period. 3.22. NPPF para 137 requires exceptional circumstances to include evidence of the examination of all other reasonable options for meeting an identified need for development. Importantly, in reviewing Green Belt boundaries sustainable patterns of development should be taken into account. 3.23. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and review growth options, where the most sustainable form of development is likely to be around existing settlements, it is therefore imperative that the Local Plan evidence base includes a Green Belt review. The Councils’ recognition of this in relation to a number of the proposed growth options is supported. 3.24. If a Green Belt boundary review is not undertaken, development will need to ‘jump the Green Belt’ which would result in an isolated pattern of development. Q-S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 3.25. It is noted that the Issues & Options document has reduced the previous seven growth options presented in the Scoping Consultation to five options as outlined above through refining and combining options, including Option 2 sustainable travel (combination of rail and bus corridor) and Option 3 economy (combination of socio-economic and enterprise hub options). In this consultation document, Option 4 sustainable travel and economy effectively combines Options 2 and 3. It is clear from this process that the growth option to be pursued will represent a combination of all five options outlined above. 3.26. The options now presented in the Issues and Options, apart from Option 5: Dispersed, perform broadly similarly to each other in the SA (Table 7.1) suggesting not one option may have significantly more or less impact than any of the others when considered against the SA Framework. At this stage, the SA has not considered any mitigation or site-specific options for growth within settlements identified within the ‘dispersed’ option (5). There could be significant variance in how each settlement and individual sites would perform against the SA objectives. All of the growth options could deliver sustainable development and a combination of all options will be the most appropriate option for the development of the Plan going forward. 3.27. By necessity, the strategy will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66 year supply of housing. Land from other sources will therefore be required and it is important that all options are considered in taking the Plan forward. 3.28. Combining sustainable travel (including rail) and economy will naturally direct most growth to the larger, more sustainable settlements. However, it is important that appropriate, proportionate growth is directed to smaller settlements in order to support the continued viability and vitality of these settlements going forward. This would include supporting or enhancing sustainable travel options at these locations. This needs to be positively planned for as part of the South Warwickshire Local Plan and as such an element of dispersal should form part of the final growth option. This will require a careful consideration of all of the options, including growth at existing main settlements, growth at smaller existing settlements, proximity to services and jobs, availability of infrastructure or opportunities for infrastructure delivery and a Green Belt boundary review to ensure development is not isolated beyond the defined Green Belt boundaries. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Q-S8.2 For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 3.29. The supporting text for this question confirms that the aim of this approach would be to allow for development within or adjacent to existing settlements. This provides greater scope of these settlements to accommodate growth than the current infill only approach. The proposed approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. 3.30. An across the board threshold limit of 10 dwellings is not supported. The amount of development different settlements can accommodate will vary significantly depending on various factors, such as existing services and facilities, local need for housing and the suitability of the proposed site to accommodate a certain level of development. 3.31. In addition, developments of 10 or fewer dwellings are exempt from affordable housing. Even where a lower threshold is set, developments of this scale generally result in a commuted sum towards affordable housing elsewhere. This is due to a variety of factors, including that registered providers often will not take on a small number of dwellings in one location. It is clearly preferable to have affordable housing delivered on site wherever possible to meet local needs. Setting a more flexible threshold that would allow for a higher level of development where appropriate would support greater on-site affordable housing provision. Q-S9: Please select the option which is most appropriate for South Warwickshire 3.32. The South Warwickshire Local Plan provides the opportunity to review all settlement boundaries and ensure they will be fit for purpose across the plan period. Saving all existing settlement boundaries is unlikely to be effective in positively planning for plan-led growth across the plan period. This should apply all settlements as part of the exercise will be to assess which settlements which would benefit from a defined boundary. 3.33. To be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. 3.34. In addition, settlement boundaries will need to be reviewed and amended to take account of new allocations. 3.35. For example, the development boundary for Harbury should be reviewed which would allow for the inclusion of this Site (Call for Sites ref: 459) within the development boundary for to deliver sustainable residential growth.

Q-S1: While the Respondent does not object to the identification of Green and Blue Corridors in principle (in accordance with Paragraph 20 of the NPPF), they are not convinced that such designations can be robustly evidenced or justified in absence of the Councils’ Local Nature Recovery Strategy (LNRS). The Respondent would therefore err towards not identifying such areas at this stage. Q-S2: Developers tend to err towards higher densities without the need for a planning policy requiring such. It is the inter-play of policy requirements and the input of stakeholders that tend to drive densities down rather than developer choice. The Urban Capacity Study (October 2022), which forms part of the Issues and Options Evidence Base, identifies the biggest constraint to the maximisation of gross developable areas on sites as being the requirement to provide private and shared parking spaces (Urban Capacity Study, Section 3.3, Page 20). Should the Councils therefore wish to optimise densities, careful thought will need to be given to the implication of other policies and requirements on the ability for developers to build at higher densities. With regard to Design Codes, while these can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design and density perspective. Since developers tend to err towards maximising the efficiency of sites anyway, the preparation of a design code simply to support intensification would seem a disproportionate response to the issue at hand. It would be better if the Councils focus on the consideration of the wider implications of policies and standards contained in the plan which are known to drive densities down. Q-S3.2: While the Respondent recognises the importance of re-using Brownfield land, having considered the options presented in the Consultation Document, Option S3.2a is considered most appropriate in South Warwickshire, with Brownfield sites prioritised only where they are sustainably located and in line with the identified growth strategy. To do otherwise could result in unsustainable patterns of development that would conflict with the overarching vision and strategic objectives of the plan. Q-S4.1: Yes. The Respondent agrees that growth of existing settlements should be part of the overall growth strategy for South Warwickshire. As opposed to new settlements, sustainable development at existing settlements has the benefit of being delivered without significant infrastructure investment and within a much shorter time frame. Turning to Henley-in-Arden, the Respondent’s site represents a sustainable and logical extension that is capable of being developed without technical impediment and would assist in supporting existing facilities and services at the town. Such matters are discussed in further detail in the site-specific representation at Section 3.0 of this Statement. Q-S5.2: Broadly yes. The Respondent is generally supportive of the inclusion of new settlements in the overall growth strategy as they can be an effective way, at least in theory, of delivering new housing where there are barriers to the sustainable delivery of sufficient housing elsewhere. However, in reality, the physical implementation of new settlements is often complex and costly, which can significantly hamper their delivery. The Respondent would therefore caution against over reliance on new settlements in the preferred growth strategy. Where new settlements are proposed the infrastructure requirements should be identified and robustly costed to ensure that delivery is viable. The Councils should also take a conservative approach regarding assumed capacity and likely build-out rates and avoid including housing completions from new settlements too early in the plan period. The Lichfield’s Start to Finish (Second Edition) 2020 report may be a helpful starting point in this regard, although any assumptions that are made will need to be fully evidenced having regard to site specific constraints and circumstances. To improve choice and competition and help to mitigate the risk and implications of such sites not coming forward within the timescales envisaged it is recommended that a buffer is applied to the housing need, with a greater number of small-medium sites allocated at sustainable settlements to ensure adequate housing delivery in the short-medium term. Q-S8.1: No. The sustainability of settlements falling outside of the chosen growth strategy will vary to a significant degree and should not therefore be treated as equal. Settlements such as Bishop’s Itchington, which is defined as a Local Service Village under Policy CS15 of the current Stratford-on-Avon Core Strategy, have the potential to accommodate significantly more growth than is being suggested in the current Consultation Document and in the interests of maintaining the vitality and viability of such settlements should not be ignored in the development of a preferred strategy; particularly where they have a good range of facilities and access to public transport services. In such cases it would seem irrational to restrict development via an unnecessarily arbitrary approach. In the Respondent’s view, a comprehensive settlement audit should be undertaken for those settlements that fall outside the identified growth strategy to better understand their functionality and relative sustainability. The results of which can then be used to inform an appropriate distribution strategy across these settlements in a less arbitrary and more transparent way. To do otherwise would put at risk the vitality of such settlements in conflict with Paragraph 79 of the NPPF. Q-S9: Of the options presented the Respondent considers that a consistent approach across Stratford-on-Avon and Warwick District is most appropriate and would therefore lean towards Option S9b as being the most appropriate option for South Warwickshire. The Consultation Document notes that one disadvantage of this option is that some non-strategic land allocations will likely not be made until Part 2 comes forward and that it would be difficult to make appropriate revisions to boundaries in advance of these non-strategic allocations being made. The Respondent does not disagree and considers this to be one of a number of disadvantages in proceeding with a two-tier plan rather than a single one as discussed further in the response to Q-P1.2.

Issue S6: A review of Green Belt boundaries To fully consider all options, the spatial growth options are presented with Green Belt policy “off”. Therefore, all five refined options include locations within the Green Belt. The Issues and Options confirms that a decision “on whether to take land out of the Green Belt are interlinked with the selection of a growth option, and the balance of Green Belt and non-Green Belt locations varies between growth options”. A large area of Stratford and Warwick is designated as Green Belt. This includes some of the larger settlements such as Alcester, Henley-in-Arden, Cubbington and Kenilworth, and subsequently the majority of the area’s railway stations with several lines running through the area covered by Green Belt. The Issues and Options document states acknowledges that “the location and spread of the Green Belt in South Warwickshire may mean that limiting growth to locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option as it pushes development away from areas that are well connected with good infrastructure and better access to facilities and services towards areas with more limited infrastructure and where further travel would be necessitated.” The Issues and Options document states that the responses to the previous consultation confirmed that 54% of respondents supported the exploration of growth opportunities in the Green Belt. HIA Developments LLP considers that a Green Belt review is necessary. In the context of the proposed Plan Period up to 2050, it seems reasonable to assess all sites, both Green Belt and non-Green Belt. HIA Developments consider that the South Warwickshire Plan should consider growth opportunities in the Green Belt where they would offer sustainable development (for example railway connections), and agree with the Issues and Options document that locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option. There has been very little growth in Henley-in-Arden due to its location in the Green Belt. The protection of Henley-in-Arden is precluding sustainable development. It is therefore considered that a Green Belt Review should form part of the evidence base, to ensure that development is not excluded in sustainable locations. Issue S7: Refined Spatial Growth Options 2.24 The Scoping and Call for Sites document proposed seven initial options for growth. These wereas follows: • Option A: Rail Corridors • Option B: Main Bus Corridors • Option C: Main Road Corridors • Option D: Enterprise Hubs • Option E: Socio Economic • Option F: Main Urban Areas • Option G: Dispersed These have been reduced to five options. The five options are: • Option 1: Rail Corridors (includes Henley-in-Arden) • Option 2: Sustainable Travel (includes Henley-in-Arden) • Option 3: Economy (includes Henley-in-Arden) • Option 4: Sustainable Travel and Economy (includes Henley-in-Arden) • Option 5: Dispersed (includes Henley-in-Arden) As identified above, each of the five spatial options identifies growth at Henley-in-Arden (albeit the level of housing requirement is not established, the indicative orange icon suggests between 1,000 – 4,000 dwellings in each spatial growth option). In a time where we are seeking to encourage more sustainable movement patterns and reduce carbon emissions as much as possible, it seems reasonable to locate development in locations which can benefit from public transport. In our view, Option 1 (Rail Corridors) and Option 2 (Sustainable Travel) should be considered essential as they offer sustainable alternatives to car travel.

I have noticed on the Call for Sites initiative that a parcel of land has been put through for a minimum of 10 house in Grove Lane, Ashow, CV8 2LE. REFERENCE ID 193 SWLP Call for Sites I would like to object at this stage to this land being considered for development as part of the local plan. 1. Greenbelt – This field forms an important part of the conservation area of the village and within the greenbelt. Inappropriate development is harmful to the Green Belt. It is difficult/ impossible to see how houses on this site would enhance the Green Belt. 2. Conservation area – the character of the Ashow Conservation Area should be preserved and we should be looking to retain the character of the area. There are numerous listed buildings that are adjacent to the land in question and important that the quality of these areas are maintained. 3. Strong Village Opposition to Development – the Ashow Parish Council hosted a meeting on Saturday with regard to the Neighbourhood plan. This meeting was very well attended. One of the exercises was to place markers on a map of the village with regard to where the community would and would not be happy to see housing development. Without exception, every resident placed red markers in all fields which would have capacity for building. It was clear to see that the residents of Ashow do not feel we need housing nor development in the village. 4. Highways – There is no public footpath along Grove Lane. The road is single carriageway. The road is often blocked due to visitors parking on the street, ceptic tank vehicles, oil delivery vehicles struggle to get past – not least if there was ever a need for the emergency services. The access to the site would either be the very narrow lane adjacent to Long Row or from Grove Lane – neither of which are suitable or practical given the single track nature of the access roads. The volume of additional cars in the village is completely impractical – the roads are congested now, and do not have capacity for more vehicles 5. Services – there is no mains drainage, and no gas supply in the village – villagers having to rely on Ceptic Tanks and Oil for heating 6. Previous Proposed Development (Application Number W/17/0778) – I refer you to a previous planning application on this land which had a significant volume of opposition. I strongly urge you to not consider this land for proposed development. It would be totally inappropriate in the village, not supported by any Policy and is overwhelmingly objected to by a significant number of villagers – which was entirely evident in the Parish Council Neighbourhood Plan meeting held on Saturday 4th March.

I have already submitted comments on behalf of the Liberal Democrat Group. I now wish to comment as Ward Member on local issues. I confine my comments to potential sites. Broad Potential Locations Substantial developments close the Chiltern Line and the spur to Kineton are unacceptable. This is a rural area generally far removed from other centres with little local or organic growth needs. It is most unlikely that rail authorities would support a rail station, even allowing for a degradation of service after HS2 comes into service. If a station such as unstaffed platforms were provided, it is unlikely the such an intermediate station would be adequately serviced as trains presently pass these points at speed and stopping trains between conurbations of Banbury and Leamington would be undesirable on energy and financially. Feeder custom from the wider area at such locations is unsustainable. Option 1, 2 and 3 The mapping shows a large development south of Southam. The Southam area has experienced excessive growth in recent years with the infrastructure overloaded (roads, health facilities, major shops). Even a well infrastructured new village would require frequent external travel to larger towns in opposition to the overarching principles. Option 4 The mapping shows a large development south of Southam, plus one to the east. In addition to comments above, the observations apply in this context as well. Option 5 Distributing development is unacceptable on environmental grounds and risk the destruction of the character of small villages and communities. Generally Constraining development to central areas of Stratford district and absolutely excluding the Green Belt and AONB has resulted in a concentration of development around Southam, Bidford, and Stratford. My own opinion is that a new settlement could preferentially be sited around Warwick Parkway Station with its existing station, and ready links to M40, M6, Warwick, Coventry, Stratford and Birmingham.

Q-S3.2: Lockley Homes would select Option S3.2c (None of these) given that the other options listed above fail to recognise the importance of sustainably located greenfield sites, and the important role that they can play in delivering new housing. We maintain our view that our site within the Village of Broom settlement should be brought forward as a matter of urgency within the SWLP Review (2023). The strong set of sustainability credentials of the Lockley Homes site is supported by robust and defendable evidence as set out in Appendix B of this Representations Statement. As a key local stakeholder, we have continued concerns that the Council’s preparing the emerging SWLP Review are ignoring the potential important role that under-utilised low quality greenfield sites, which have strong physical connections to long established existing village settlements, can play in helping to meet longstanding housing shortfalls present across the SWLP Local Plan area to help meet the development needs up until the year 2050. The Council’s unreasonable and highly obstructive planning policy position and stance being taken towards these types of sites fails the ‘Sustainability’ Local Plan test of ‘Soundness,’ as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). There is a severe shortage of brownfield sites (previously developed land) available across the SWLP area to meet identified housing needs and longstanding housing shortfalls, given that the SWLP districts are both dominated by open countryside. Therefore, the important role and contribution that low quality, under-utilised green space areas (such as former paddock land), in well-integrated locations within the confines of existing village settlements can make towards housing supply should be increasingly recognised by the LPA’s preparing the emerging SWLP. Our views on this issue are supported by an extensive range of guidance from the Revised NPPF (2021). Most notably, paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should already be aware of this NPPF guidance and its critical importance to Local Plan-making. The position is perfectly, this highly obstructive planning policy approach, ongoing failure, continued refusal and continued incompetence being taken towards Local Plan-preparation by the Council’s Planning Policy Teams, means that the emerging SWLP Local Plan Review (2023), even at this very early stage in its Local Plan preparation, is already currently failing the ‘Sustainability’ test for Local Plan preparation tests of ‘Soundness’, as set out within paragraph 35 (indent d) of the Revised NPPF (2021). The emerging SWLP Local Plan Review (2023), alongside its sister document Stratford-on-Avon District Council’s unsound and not-fit-for-purpose emerging Site Allocations Plan (SAP), are both therefore vulnerable to future Legal challenge at the later Examination in Public (EIP) stage. Given their continued failure and ongoing refusal to promote the most sustainable patterns of new housing development across the South Warwickshire Region. It is important that these ongoing, long-standing failings discussed above are now addressed within a revised planning policy approach being taken forward within the emerging SWLP Review, at its remaining Plan-preparation stages. As a key stakeholder, it is important that we highlight these failings to help strengthen the approach being taken towards future Local Plan making, to help the Council’s deliver a ‘Sound’ and ‘Legally compliant’ Local Plan, which meets the various tests of Soundness as set out within paragraph 35 of the Revised NPPF (2021). Q-S4.1: Yes, the growth of some of the existing settlements should be part of the overall strategy. This approach would correspond well with guidance in paragraph 79 of the Revised NPPF (2021). Paragraph 79 of the Revised NPPF (2021) states that: “…To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby…” In accordance with the above NPPF guidance, Lockley Homes would suggest that the Council’s emerging SWLP (2023) should consider the future housing-led growth and sustainable expansion needs of existing rural village settlements located across the South Warwickshire Region. This matter should be one of the key spatial planning policy priority areas for the emerging SWLP Review to consider, in order to help deliver a ‘More Positively Prepared Local Plan,’ and to allow the Plan to promote the most sustainable patterns of development - consistent with the ‘Sustainability’ tests of Soundness for Local Plan preparation as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). Proposed housing sites such as the Lockley Homes site located within the Village of Broom settlement should be brought forward for new housing development in the SWLP as a matter of urgency, not left for consideration within a future Stage 2/ version 2 of the SWLP in many years from now. We have ongoing concerns that the Council’s preparing the emerging SWLP and its sister document – Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP), are failing to promote the most sustainable patterns of new housing development within these Local Plan Reviews. This will mean that the Plans are vulnerable to future Legal challenge as they are both failing to comply with the Sustainability test as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). The position is quite clear, substantially less sustainable new housing development site locations are being strongly favoured by the LPA’s and strongly promoted, whilst more sustainable site locations are being completely ignored and overlooked by the LPA’s preparing the above Local Plan Reviews. We have concerns about this ongoing failure and continued incompetence being taken towards Local Plan preparation. Lockley Homes maintains its view that new housing development sites coming forward within the Stratford-on-Avon District and wider South Warwickshire Region within the most sustainable site locations, should be strongly encouraged, prioritised for new housing development first, before other less sustainable site locations are allocated for new housing, and should be considered very favourably within the emerging Local Plan Review process without unnecessary delay. To help meet the urgent housing needs of local communities within the South Warwickshire Region, and to help pro-actively address long-standing housing shortfalls present across the SWLP area. This approach accords strongly with current Government policy which is now governed by a pro-growth National Planning Policy Framework which gives a presumption in favour of sustainable development, and guidance in paragraph 60 of the Revised NPPF (2021) which emphasises the need for LPA’s to significantly boost the supply of new homes across the United Kingdom. General comments: The Sustainability Appraisal (SA) being used to support the emerging SWLP (2023) is not promoting the most sustainable patterns of new housing development to the most sustainable site locations within the South Warwickshire Region. Stratford-on-Avon District Council’s Planning Policy Team is showing a very strong level of support and notably biased favouritism towards significantly less sustainable site locations by prioritising the delivery of new housing development sites located in isolated and very peripheral farmland locations. Distantly located away from the main existing rural village settlement cores, in areas of distantly located farmland countryside, on the very outer fringes and periphery of existing rural village settlements. The Council’s unreasonable and highly obstructive planning policy position and approach being taken on this issue fails the ‘Sustainability’ test of ‘Soundness’ for Local Plan preparation, as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). On this basis, both the accompanying Sustainability Appraisal (SA) being used to support Local Plan-preparation, and the emerging SWLP (2023) are both in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for LPA’s to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Our concerns on these issues are already covered within this wider SWLP Representations Statement (March 2023), as well as our Representations to Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (2022). Q-S10: We have concerns that the LPA’s preparing the emerging SWLP Review (2023) are failing to promote the most sustainable patterns of new housing development across the South Warwickshire Region. Lockley Homes maintains its view that the Council’s preparing the emerging SWLP Review (2023) should be focusing new housing development proposals towards sustainably-located infill sites within and on the edge of existing rural village settlements, in accordance with guidance in paragraph 79 of the Revised NPPF (2021). Lockley Homes has a perfectly acceptable site location suitable for new housing development. For reasons already set out within this wider SWLP Representations Statement (March 2023), this site should be supported within the emerging SWLP Review, not left for a future Stage 2 of the SWLP Local Plan to consider in many years from now. Stratford-on-Avon District Council’s Planning Policy Team is showing a very strong level of support and notably biased favouritism towards significantly less sustainable site locations by prioritising the delivery of new housing development sites located in isolated and very peripheral farmland locations. Distantly located away from the main existing rural village settlement cores, in areas of distantly located farmland countryside, on the very outer fringes and periphery of existing rural village settlements. The Council’s unreasonable and highly obstructive planning policy position and approach being taken on this issue fails the ‘Sustainability’ test of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). As well as an extensive range of other guidance from the Revised NPPF. Most notably, paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for LPA’s to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Our concerns on these issues are already covered within this wider SWLP Representations Statement (March 2023), as well as our Representations to Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (2022).

I live in Wootton Wawen and understand that the Parish Council is going to suggest more housing adjacent to Denis Keyte Gardens instead of the areas proposed. My concern is whether the drains could cope. It has been at least a three-time yearly event for traffic cones to go up to close part of the A 3400 so a repair can be done. Could not a playground be incorporated in the plans for this area? There is always discussion for the need for housing for young families but now the school playground is hazardous there is nowhere for young families to go to. One last comment is my concern for the red cedar trees which line the drive along Blackmore Mill (a proposed area for Henley's local development). These trees are very mature but, as an old hedge recently quickly disappeared along our road for new housing, I would think these trees would disappear. All the best in your efforts to improve the lives of all in Warwickshire - indeed this must be extremely hard.

I struggle to understand how Wootton Wawen could be capable of supporting an additional 500 homes. A lot of the land in and around the village is green belt or flood plain which would prevent any construction. 500 homes would also represent a more than doubling of the size of the village which is far beyond the scope of reason. The additional homes would significantly increase the traffic levels which would be a detriment to the local area not to mention increase safety concerns given the current level of speeding that takes place. There is a character and beauty to the village that is enjoyed by many visitors, not just the residents. Adding such a large number of homes would alter this irreparably. I believe the village is suitable for a handful of new homes, built in small pockets, and no more.

1. WINDFALLS • The SWLP allows for land for 220 dwellings per annum (DPA) from windfalls. • Actual annual average windfall numbers since 2011 have been 901. • 69% of Stratford’s housing site needs since 2011 have been met from Windfalls; 44% of Warwick’s. • If instead of 220 DPA’s (as in plan) the SWLP assumed only half the annual average, (450 homes) the housing land shortfall drops from 23,000 to 1510 in 2040; 5,410 in 2045 and 9310 in 2050. • If the actual average since 2011 – 901 - is used, the plan is in surplus: 5,255 excess house spaces in 2040; 3610 excess in 2045. 1965 in 2050. • In addition to a severe underestimate of overall numbers, the Local Planning guidance only includes within the 220, those spaces for fewer than 9 dwellings. So places like the Ford Foundry site, the King’s High School sites, land adjacent to Leamington Spa Station, and others for more than 9 houses would not be included. • We believe that this also seriously distorts likely available land, based on figures since 2011. 2. AFFORDABILITY UPLIFTS • Under a formula devised in 2004, housing numbers are automatically increased in more expensive areas, on the assertion that building more houses will bring down prices. • This has nothing whatsoever to do with actual housing need. • ONS numbers from the base year used (2014) assessed the SWLP area need at 874 homes. The Affordability formula increases this to 1,239. These are the numbers used in the SWLP. • This is an increase of 42% over need. 3. IN-MIGRATION • Housing numbers like Coventry’s encourage net in-migration to local areas. They are not a response to endogenous growth. • 76% of Warwick’s estimated population growth for 2018-2028 comes from net in-migration. • 118% (!) of Stratford’s is from the same source. • This therefore risks becoming a self-replicating cycle. (“We’ve filled more houses, therefore we need more houses, therefore…”) 4. DUTY TO CO-OPERATE • Housing was built in the SWLP area as a response to Coventry’s overestimates, destroying swathes of prime farmland in the process. • This is part of the ‘Duty to Cooperate’ imposed on neighbouring areas, when the ‘growing’ area does not have the requisite space. • The government has added 35% to assessed need in 20 key cities. (In theory this means that more urban brownfield sites are used.) Applying this to Birmingham gives them three times their demographic need. • Birmingham does not have space for these numbers. • This potentially means that over the plan period South Warwickshire will have to build houses they don’t want for a Birmingham need that doesn’t exist. • The Black Country has currently paused its Local Plan for similar reasons. 5. EMPLOYMENT LAND NEEDS • We would ask those responsible for the SWLP to reconsider Employment land needs. • Numbers don’t reflect the estimated 30% reduction in office space post-Covid. • There is also a visible increase in Town Centre vacant retail sites across the region. • In particular, Stratford is estimated to need 132.8Ha (333 acres) of Industrial Land. • This puts it only behind Rugby (Cement and extraction) and Coventry (automotive). • We have asked for an explanation of how this number was derived. 6. TIMEFRAME • The SWLP framework extends from 2025 to 2050, to allow for long-term infrastructure planning. • This is considerably longer than most planning frameworks. • Increasing the plan from the more usual 15 years, increases SWLP housing numbers by 50%. (And therefore countryside blight). • Remaining with 15 years, instead of 35,000 houses by 2050 we would be looking at 23,370 by 2040.

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

Following on from the comments made to Issues S4 and S5, consideration should be given to directing more development toward new settlements such as LMA. Intensifying the site would help deliver sustainable development in a location already deemed suitable. The proposals will ensure that the additional dwellings are kept within the confines of the site boundary and that the other uses to be delivered (community, employment and open space) will remain.

SAVE OUR GREEN SPACE To Planning Department, Warwick District Council, In the context of the proposed housing developments on farmland and green spaces in Kenilworth we wish to object in particular to the proposed development opposite Crackley Crescent. In the last few decades we have lost much of our rural environment, and above all have been subjected to noise and intrusion from the construction of HS2. This proposal would finally destroy what is left of the green belt between Coventry and Kenilworth. Under these circumstances we strongly oppose any development in this area including the proposed Strategic Link road.

Sherbourne response to SWLP – March 2023 The residents of, and Parish Councilors for, Sherbourne have some grave concerns over the likely over-development of Sherbourne and the complete change to its current rural small village nature, should many of the sites listed in the draft local plan go ahead. The SWLP already identifies Sherbourne as a ‘Limited Infill’ village and that is a realistic description of the village. It has no sustainable infrastructure that will be able to support any significant building whether for housing or commercial properties. Sherbourne does not have the following: • Shop • Pub • School • Employment opportunities • Footpaths on most of the roads – with the exception of one side only of Church Road and one side of Fulbrook Lane. The nearest local services are one mile away in Barford, all of which necessitate crossing the very busy A429, which is planned to become a lot busier, or in Warwick 3-4 miles away which necessitates crossing the A429 and the M40 Junction. It does have a bus service but this is infrequent and not suitable for regular commuting to either Stratford or Warwick/Leamington for work. Therefore any additional house building in Sherbourne will have to have all their transport needs met by private cars, adding further to the traffic on surrounding roads and contravening SDC and WDC planning policies. The interactive map has large swathes of land around Sherbourne marked as having the potential for industrial / commercial development primarily around the A46 / M40 Junction – Both sides of the A46 north of the junction – The north side of the M40 between J15 and J14 – The south side of the m40 between the River Avon and the junction If all this goes ahead this will turn the outskirts of Warwick into an area akin to the M40 approaches to Bicester with all available land covered in large industrial or logistics buildings. While a desk-placed planner will look at the maps, see some logic to this and think the road network is ideal for this, it will change the whole nature of the southern approaches to Warwick. This will spill over and surround Sherbourne completely destroying its rural character as a small estate based village. As the definition of ‘limited infill’ describes, Sherbourne has the potential for some infill, a couple of houses at most, on sites in and around the village, but its total lack of infrastructure means it cannot handle anything more. The following are our responses to the Sherbourne sites listed in the call for sites are shown in the table below. For information the people identified as ‘Sherbourne Owner Occupiers’ is the local residents association concerned about protecting the village and they are not proposing the sites identified should be developed. Comments have been added below each site where appropriate. 181 Land South of M40 Junction 15, Longbridge Warwick Field to the east of Watery Lane Turley Employment / Industrial / Commercial 181 – this is one of the most worrying of the potential sites. The suggestion is that this be turned over to distribution warehouses. From a desk based planning approach this may seem logical, it is just off the M40 and adjacent to the A429 which is already a major route to the Distribution Centre in Wellesbourne, so the argument would be that there wouldn’t be much extra traffic. Site 181 covers two parcels of land one of the west side of A429 and one on the east side. Firstly this parcel of land is in the flood zone which should make it unsuitable for any such development. Secondly, although it is on the A429, this is a relatively short stretch of road and it would be very difficult to create a road junction large enough to handle HGVs turning in and out of a distribution site. Rush hour traffic already causes tailbacks from the roundabout down the A429 to Fulbrook Lane, and sometime beyond, which is all well past where a distribution depot entry would be needed. There are already traffic problems on that part of the A429 with HGVs who park overnight in the laybys or on the access road to the Highways Depot in the corner of the M40 junction. Thirdly and most importantly any such warehouses would tower over all the houses along Watery Lane, the cottages at the end of the Stratford Road and all the houses in Moat Green. This would change completely the nature of this side of the village visually, plus would also subject the whole area to a vast increase in noise from HGVs which would inevitably need to work 24 hours a day to make any sort of distribution centre a viable proposition. Interestingly one possible use for this site does not seem to have been considered. Developers have already submitted planning applications for solar farms at two locations on the green belt farmland to the north of the A46 adjacent to the Sherbourne roundabout. One of these has been rejected for green belt and associated reasons. The second application is going through the system at time of writing (March 2023) and assuming the refusal of the first application sets a precedent, this is likely to be refused. This site 181 – could usefully be used as a solar farm. It has a large south facing open aspect, the solar panels are normally installed on piles taking them above ground level and could be mounted high enough to not be at risk of flooding. Significant access would only be required during the construction phase and following that, there would be minimal access and traffic requirements and no increase in A429 volumes. The size and nature of the solar panels should all be low enough to be screened from the Sherbourne residents by the current hedge and tree planting along Watery Lane – although this could benefit from some improvements. 196 Land east of Vicarage Lane Sherbourne Pegasus Group Housing / residential 196 - This is known as the Black Barn Paddock in the village, and currently is used for grazing animals – normally horses. It contains a large metal barn which in the past has been used for stabling /livery. Despite the size of this site, it is not suitable for the development of a large number of houses due to the lack of village infra-structure mentioned. At best if it were to be developed then it could support a couple of large properties along Vicarage Lane and a couple along Watery Lane. All residents would still be reliant on Barford, Warwick etc for infra structure and while there are no employment opportunities in the village this should not generate significant amounts of traffic in the lanes. 201 Land between Vicarage Lane and Watery Lane, Sherbourne Sherbourne, CV35 8AL Godfrey Payton Housing / residential 201 - this paddock is between Watery Lane and Vicarage Lane with Fulbrook Lane along its southern boundary and is also used for grazing, currently for goats (as a petting zoo type of attraction) with a parcel of the paddock sectioned off for dog care / walking. Even this minor use is causing problems in the village with site visitors parking either on the grass verges, or part on the verge, part on the lane, narrowing the already limited access. For all the reason listed above this site is not suitable for a significant housing development. 364 Land south of M40 Jctn 15 Nr Sherbourne, Warwick Stoford Developments Ltd Employment / Industrial / Commercial 364 - is similar in nature, and adjacent to Site 181 and our objections are similar Again this area is in the flood zone making it unsuitable. While any such development would not be as close to the Sherbourne housing as Site 181, and therefore not be as over-bearing, this would change the nature of the area from the M40 down towards Barford. 533 (a) Black Barn Paddock (Sherbourne Farm) Sherbourne Owner Occupiers Open Space / Biodiversity / Green Infrastructure 533 (a) see comments above for 196 533 (b) Corner Paddock/Ryefield Corner of Vicarage Lane and Fulbrook Lane Sherbourne Owner Occupiers Open Space / Biodiversity / Green Infrastructure 533 (b) see comments above for 201 533 (c) The setting of Sherbourne Priors Sherbourne Owner Occupiers Open Space / Biodiversity / Green Infrastructure 533 (c) has recently been the subject of a planning application W/22/1508 for two houses to be built within a portion of the grounds of Sherbourne Priors (Grade II Listed Building) which has now changed use from a Language School back to residential. A portion of the land was retained by the last owners who planned to build on it. While the addition of two houses in the village and the limited traffic they would generate would not have had an overly adverse effect on the village, the application was refused by WDC on the following main grounds: The siting and design of the proposal are considered harmful to the character and appearance of the area, the Conservation Area and the setting of the Grade II listed building. 533 (d) Land at the north end of Church Road Sherbourne Owner Occupiers Open Space / Biodiversity / Green Infrastructure 533 (d) is a small parcel of land on the corner of Church Road and Fulbrook Lane. This is currently used for grazing sheep and while it is potentially large enough to build one house, portion of it does flood regularly as Sherbourne Brook flows along its western edge. 533 (e) Coplow Hill and surrounding farmland Sherbourne Owner Occupiers Open Space / Biodiversity / Green Infrastructure 533 (e) is a large tract of land with Fulbrook Lane to the south and the A46 to the north. This is a steep sided hill, some of which is wooded (Coplow Wood) and most of which is used for dairy farming on a long lease. This land should be retained for agricultural and open space purposes. A number of ‘glamping pods’ have been installed in Coplow Wood in the past few years and these have had minimal impact on the area and residents, and in fact are invisible from Fulbrook Lane below the woods. It has been intimated that the landowner may wish to install a few more pods and as long as the number is not excessive and then are no ancillary building proposed, then the site could sustain this level of development. 533 (f) Watery Lane and A429 Sherbourne Owner Occupiers 533 (f) see Site 181 533 (g) Fields adjacent to A46 Sherbourne Owner Occupiers Open Space / Biodiversity / Green Infrastructure 533 (g) relates to the fields on the north of the A46 adjacent to the m40, the Sherbourne roundabout and heading up the hill towards Stratford. This land has been the subject of two planning applications for solar farms: W/22/0548 Which has been refused by WDC W/22/0997 now re-submitted as W/23/0150 mentioned above which is currently going through the Planning Application process. Both these sites raise an interesting conundrum. Firstly they are in green belt and good agricultural land so in principle should not be used for development and should continue to be farmed. However, over time the rules around green belt have been known to change and we do not know how/if they will change in the future. If some of the other proposals go ahead much of the land around the M40 J15 and A46 could well end up as industrial/ commercial / distribution used. So while the local preference is that the land should remain in agricultural use, having solar farms on the land for an initial 40 year lease period, would effectively neutralise it and save it from commercial development for at least the next 40 years.

9. Land North of Mill Street, Harbury 9.1. Rainier Developments is promoting land north of Mill Street, Harbury for residential development, including on-site public open space. 9.2. The land comprises of two adjoining agricultural fields, each field is defined by hedgerow and tree planting. The existing built development to the north of Mill Street is excluded from the site boundary (please see Concept Masterplan enclosed at Appendix 3). 9.3. The area is characterised by existing residential development and associated local services and facilities. It is notable that existing built development on Mill Street extends further north on land to the east and west of the Site. The Concept Masterplan has carefully considered the existing built form and settlement pattern. This is reflected in the concentration of built development towards Mill Street, with proposed open space, play facilities and sustainable drainage systems proposed towards the northern boundary. 9.4. Harbury benefits from access to a range of local services and facilities, notably Harbury Surgery, Harbury Primary School, Village Hall and playing fields. There are existing bus stops throughout the village which provide services to Leamington Spa, Southam and Long Itchington. 9.5. It should be noted that the currently adopted Core Strategy identifies Harbury as a Category 1 Settlement alongside Bishop’s Itchington, Long Itchington, Quinton and Tiddington. This clearly reflects that settlement is a sustainable location for growth and the South Warwickshire Plan should reflect this. 9.6. It is also of relevance to note that this Site was identified as a reserve housing allocation in the December 2020 Site Allocation Plan Preferred Options (prepared by Stratford-on-Avon Councill: Site Reference HAR.C*). This clearly demonstrates that the Council has previously assessed the site and concluded it is suitable to accommodate residential development. The only reason the allocation was omitted in the July 2022 Preferred Options SAP was the Council considered Harbury had met its housing development apportionment and did not require further development at this time, under the Core Strategy. Representations were submitted at the time to query this approach however, of relevance to the South Warwickshire Local Plan, is that the proposed allocation was not omitted due to any overriding constraints that would preclude the development of this Site for residential use. 9.7. A Landscape Position Note (enclosed at Appendix 4) sets out that the site makes a limited contribution to the Feldon landscape and that the Site could be developed without undermining the local landscape character. Sustainability Appraisal (SA) 9.8. The settlement has not been identified as a ‘Small Settlement’ within the SA. At Figure 3.4 the SA sets out the procedure for identifying reasonable alternative small settlement locations, these are replicated below, with additional commentary regarding Harbury added in italics: • Over 50% of the potential location should be within 400m if the small settlement edge. This is achievable for Harbury. • Over 50% of the potential location should be within 800m of a least one of the following services: public transport access point (train station or bus station), GP surgery, a primary school, a local shop and/or publicly accessible green space. This is achievable for Harbury which has bus stops, a GP surgery, a primary school, a local shop (Cooperative Food Shop) and publicly accessible green space (for example the play area and playing fields co-located with the Village Hall. • Over 50% of each field/land parcel does not coincide with a constraint including Flood Zones 2 or 3, AONB, ALC Grade 1, Scheduled Monuments, SSSI, Registered Parks and Gardens and ancient woodland. This is achievable for Harbury as there are no areas of flood zones 2 or 3 adjoining the village, the closest AONB is the Cotswolds which is well separated from the settlement (south of the M40), the Natural England ALC maps show no Grade 1 land around the settlement, the closest SSSI is Harbury Railway Cutting SSSI to the north however this could be avoided by much of the land around the settlement (including this Site), the are no registered parks and gardens in proximity of Harbury and the closest ancient woodland is located to the south circa 1.4km from the southern edge of the settlement. • Sports facilities and publicly accessible greenspaces are included in the potential location, although it is assumed that these would be retained. There are existing playing field facilities on the southern edge of the settlement. The rest of the settlement surroundings are not constrained by existing sports uses. • Farms and private residential properties are excluded from the potential locations where practical. This Site demonstrates this approach and this could be taken across Harbury. • Only greenfield locations, such as agricultural fields, have not been included. The identification of small settlements locations does not include Previously Developed Land. The land surrounding Harbury is majority greenfield, agricultural land. 9.9. It is clear that Harbury meets the criteria outlined in the SA to be considered as a small settlement however it has not been. It is not clearly set out in the SA why certain settlements, such as Harbury, have not been included and therefore all reasonable alternatives have not been considered. Harbury should be assessed as a small settlement, suitable to accommodate growth, and the next iteration of the SA should include this. Summary 9.10. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.11. The Concept Masterplan indicates how a residential scheme can be achieved having regard to the site constraints and opportunities. 9.12. The site benefits from a sustainable location within Harbury and is well placed to meet the housing needs of the area. The site is well-placed to ensure easy access to a range of services and facilities including public transport. 9.13. The Concept Masterplan shows how the site would follow the existing building line along and settlement pattern of Harbury through the location of open space towards the northern part of the site with built development in the southern part of the site around Mill Road. 9.14. The site is not subject to any statutory nature or heritage designations. The site is entirely within Flood Zone 1 which represents the lowest risk of flooding. The Site could deliver sustainable drainage systems (SuDS) as part of any development. 9.15. In view of the above, there are no known constraints which would prevent development of this site. 9.16. Rainier have a land interest in the Site and are promoting the site for residential development. The Site has already been submitted as part of the Call for Sites exercise associated with the Scoping Consultation in 2021, and accompanying representations were also submitted. 9.17. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.18. Rainier’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation and previous representations throughout the preparation of the South Warwickshire Local Plan. 9.19. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.20. Rainier have a land interest in this Site and are actively promoting the Site for residential development. The site is immediately available and could deliver housing in the early part of the Plan period.