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

The preamble states that Chapter 4 of the IO document sets out various options as to how the development needs to 2050 (e.g. infrastructure, jobs and housing) might be met. The approach to doing this is split into two sub-sections covering 15 ‘issues’ across both topics; on relating to ‘Development Requirements’ and the other ‘Development distribution strategy’ for the area. 3.59 Paragraph 16 of the National Planning Policy Framework (NPPF) requires that plans contain policies that are ‘clearly written and unambiguous’. In order to establish a clear and unambiguous plan it is critical that the approach to strategic policies follow a logical process. Whilst the title of this chapter may refer to ‘needs’ scant reference is made here to the nature or scale of development needs that should be addressed in the SWLP. Specifically, there is very little, if any, consideration at the top of the document to the growth needs of the area in terms of the level or scale of growth to be planned for in the SWLP. Instead, after setting out the draft vision and objectives in chapter 3, the IO document moves straight into considering issues that have a very limited relationship to the growth needs of the area. RPS would suggest that the five issues identified under ‘Development Requirements’ are generic topic-based factors that do not inform the identification of the growth needs for the area or the requirements or targets that might be necessary to address those needs. It is therefore unclear why these considerations have been given such elevated status at the beginning of the document. 3.60 RPS notes that issues relating to the number of homes and jobs that might be required, and the evidence base to justify the approach, is set out in chapter 5 of the IO document (RPS responds to this under separate questions). Whilst providing some clarity, RPS would suggest that given the importance of setting out the growth strategy (or options at this stage) a more sensible and logical approach would be to consider the issues relating to the overall development needs of the area in quantum terms first, before then moving on to consider what the requirement should be in light of the various ‘issues’ i.e. constraints, as identified here. This then provides a clearer and more logical basis for considering the spatial distribution of growth (and options) considered later on (Issue S7) 1 At present, therefore, the way the IO is structured is illogical and confusing and does not help the reader to understand the approach being proposed. RPS therefore recommends that the next iteration of the SWLP is reorganised to provide a clear position on the growth strategy at the outset, including the scale of need and the requirements defined to meet that need. This will provide a coherent basis for the spatial distribution strategy, taking into account the various issues identified.

Please find below my argument for not proceeding with any potential building works on the green area between leamington and Kenilworth. It’s used by myself and endless dog walkers It’s used by many enjoying a family walk to the Saxon mill establishment There is already too many new houses by Sainsbury’s, and not enough schools and infrastructure for leamington as it stands It’s starting to merge too much with Kenilworth It’s a working field, hence great tor nature Please take this email as a vote for no building permits to be issued and to keep it as a green space

1. I wish to strongly object to any aspect of the plan suggesting that the Green Belt should be subject to development. I have an allotment in north Leamington and over the years have seen repeated attempts by developers to build on this site. Such a move would not only destroy what makes this part of Leamington an attractive place to live and work, but also undermine our environmental, food security and sustainability commitments at both local and national level. The government has made clear that preservation of the Green Belt should be prioritised for its role in sustaining the health and well-being of local communities, as well as to ensure that the catastrophic onslaught on our biodiversity and green spaces is halted. Building on existing brownfield sites, at higher levels of density, may not be as popular with developers, but it would be following policy guidance. The District Council should be aware of the enormous power of community feeling around this issue.

Q-S1: Please select the option which is most appropriate for South Warwickshire As shown on the Vision Document (Appendix 2) and Concept Masterplan for land north of Leamington Road, Long Itchington, it is proposed to retain and enhance the majority of the existing landscape fabric, including the central hedgerow which will form a green corridor through the site. SuDS will also form an integral part of the development’s green infrastructure, providing ecological benefits and habitat creation, as well as performing their principal function of controlling and managing the flow of surface water run-off during periods of heavy and persistent rainfall. The proposals will deliver a number of landscape benefits, including new Public Open Space, play facilities and recreational routes. The promotion site is located adjacent to an existing area of Public Open Space, comprising a community park known as LILAC Field or Green End Park. This area is managed by the Parish Council and contains sports and recreational provision, including play areas, a skate park, outdoor gym and playing fields. In addition, the northern part of LILAC Field contains orchards, a picnic area and memorial garden. It is proposed to create a village green within the promotion site to the east, forming an extension of LILAC Field into the site. New planting will include generous green buffers along the western and northern boundaries of the site. Therefore, the proposals for land north of Leamington Road, Long Itchington demonstrate that green and blue infrastructure can be incorporated into development in many forms. It would be advantageous for additional evidence from the emerging Sub-Regional Green Infrastructure Strategy to be made available as soon as possible in order to inform the proposals for the Site. Therefore, Option S1a would be preferable, considering the production of a Local Nature Recovery Strategy will come after the SWLP Spatial Growth Strategy has been determined.

National Highways welcomes the opportunity to comment on the South Warwickshire Local Plan Issues and Options document, ahead of upcoming public consultations. The document outlines the challenges and opportunities that South Warwickshire will face up until 2050. The Local Plan Issues and options also sets out the visions and objectives of the local plan describing how these challenges and opportunities will be addressed. National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth. In relation to South Warwickshire, National Highways’ principal interest is ensuring the safe and efficient operation of the SRN, notably the M6, M40, M42, A45 and A46 Corridors. In responding to Local Plan consultations, we have regard to DfT Circular 01/2022 - Strategic Road Network and the delivery of sustainable development (‘the Circular’) which sets out how interactions with the Strategic Road Network should be considered in the making of local plans. Paragraph 26 of the Circular sets out that: ‘The NPPF prescribes that transport issues should be considered from the earliest stages of plan-making and in development proposals so that sustainable transport can be promoted. In relation to the preparation of local plans and spatial development strategies, the government expects that the relevant authorities will engage with the company from the outset of this process, to understand the interaction between land use designations and the impacts on road safety and future performance of the SRN.’ In addition to the DfT Circular 01/2022, the response set out below is also in accordance with the National Planning Policy Framework (NPPF) and other relevant policies. Based on our review of the Issues and Options document, reports and other supporting documents, we have identified the items below where further information is required to help support the development of the draft plan. Issues and Options Consultation Question Responses We have reviewed the document produced for public consultation relating to the South Warwickshire Local Plan Issues and Options. Based on this appraisal we provide comments to the following relevant consultation questions. Other Comments As commented on above, National Highways recommends that a Strategic Transport Assessment be produced to support the Local Plan. To enable this key piece of work we would recommend the setting up of a Transport Working Group who can work with you as the Local Planning Authority to agree the methodology, assessments, and infrastructure requirements to support the plans development and adoption. We have recommended this approach in other areas and this has aided discussions. Alongside the local planning authority and local highways authority, we consider other stakeholders who could be part of the working group could include Transport for West Midlands, Midlands Connect, and other neighbouring Local Highway and Public Transport Authorities. In addition to the above, we will actively work with you to develop and draft a Statement of Common Ground throughout the Local Plan process. Once again, National Highways welcomes the opportunity to comment on the South Warwickshire Local Plan Issues and Options Consultation. We look forward to working with you in a collaborative manner to aid and support the development and adoption of the new local plan for South Warwickshire. In the meantime, if you have any questions or comments then please do not hesitate to contact me on the details provided, and through our email address: PlanningM@nationalhighways.co.uk

I am extremely concerned by the apparent lack of consideration of the limitations of the local infrastructure in the proposals for extra settlement in and around Henley In Arden. The roads around Henley in Arden struggle to cope at peak times but this is worsened by the fact that Henley In Arden is regularly used as the relief or alternate route when the M40 and/or M42 are closed. The traffic levels are not currently being adequately catered for and substantial additional traffic will make this issue worse in addition to affecting the historic architecture in Henley in Arden. If any significant increase is considered in the Henley in Arden area it will require to be supported by additional capacity on the roads from Redditch to Warwick and Hockley Heath to Startford. There is no method of delivering additional capacity through the medieval street layout in Henley In Arden and substantial by-pass works would be necessary. The capacity would be better sited immediately adjacent to the M40 or Stratford to Warwick road where additional traffic capacity is available

At present, therefore, the way the IO is structured is illogical and confusing and does not help the reader to understand the approach being proposed. RPS therefore recommends that the next iteration of the SWLP is reorganised to provide a clear position on the growth strategy at the outset, including the scale of need and the requirements defined to meet that need. This will provide a coherent basis for the spatial distribution strategy, taking into account the various issues identified.

I am writing in response the “call for sites” publication. It appears that green belt sites in North Leamington that it had been agreed to exclude form the 2017 Warwick Local Plan are now being reconsidered for development. WDC’s stated policy is to apply National Planning Policy. The NPP framework’s position on protecting Green Belt was updated in July 2021 and if anything this has strengthened the arguments for protecting Green Belt land from urban sprawl in order to keep land permanently open. It further states that once Green Belt boundaries are established these should only be altered where exceptional circumstances are full evidenced and justified. This has not been done. The 5 fundamental purposes of Green Belt land have been identified: • To check unrestricted sprawl of large built-up areas; • To prevent neighbouring towns from merging into one another; • To assist in safeguarding the countryside from encroachment; • To preserve the setting and special character of historic towns; • To assist in urban regeneration by encouraging the recycling of derelict and other urban land. All of these purposes are clearly demonstrated by the Green Belt north of Leamington Spa and therefore the land in the Green Belt should not be developed. Site 174 • Site 174 has a clearly defined boundary along Leicester Lane. • This portion of Green Belt checks the unrestricted sprawl of North Leamington, in particular Lillington and Cubbington, into Blackdown which would otherwise lose its separate identity and be merged into one. • The openness of the Arden Landscape towards Blackdown is particularly praised in your own study of 2009. In fact at the turning with Westhill Road there is a sign designating a Leisure Drive. • There is a public footpath through the land that has been extensively used by North Leamington families throughout the pandemic and since. It is a valuable leisure resource which can be accessed on foot by those living in a more built up area to enjoy the open nature and views of typical of Arden Landscape. Thus the parcel of land according to the NPP framework should not be considered for development. Green Belt Parcels WA6 RL1 RL2 The planning inspector’s comments when this land last came up for consideration were: “Development of the land in questions 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 an appearance of the area.” The purpose of the Green Belt in keeping the historic towns of Leamington and Kenilworth distinct is vital here. With the development of land at Thickthorn bringing the urban area of Kenilworth right up to the A46, the Green belt on the Leamington side of the A46 has become even more important. This becomes even starker when taking into account the fact that the Green Belt has already been eroded by the construction of HS2 through Stoneleigh Park and beyond. The NPP framework is there precisely to check incremental incursions of this kind to the boundaries of the Green Belt and now is the time to prevent more damage being done to the historic nature and open landscape of this part of South Warwickshire. The area which is crossed by footpaths is of great value to the residents of the built up areas who used it extensively through the pandemic and since. For them to be walking through a housing estate rather than across open rural landscape would be a significant loss. Furthermore I understand that farmland in this area is of extremely high value and in the current geopolitical climate its importance to the production of food cannot be underestimated. Finally in the same way as the historic approach to Warwick has been preserved, the historic approach to Leamington as a historic town situated in an open Arden landscape should not be compromised.

I wish to record my opposition to any suggestion that land in the Parishes of Old Milverton and Blackdown and generally land to the north of Leamington Spa should be earmarked for development of housing and associated purposes. It is essential that the gap between the towns of Leamington Spa and Kenilworth be maintained and not gradually eaten up by development which could see the two towns blending in due course. This is valuable agricultural land which is a vital commodity especially in the present circumstances and should not be eroded. The areas in question provide essential green open countryside for the benefit of local people which is an important consideration in fostering good exercise to benefit health. The area is designated as part of the Green Belt and there are no special circumstance to justify eroding it.

It has come to my attention that there are plans to develop the green belt north of Leamington and that the council will be selling the land to Wimpey to build houses. There has already been extensive housing development in the south of leamington and now there is no green belt that separates the town from the M40. To the West of the town it has merged into Warwick so there is not green belt there except for the river. To the East of the town we have the HS2 that has taken a huge chunk of the green belt. To the south of Kenilworth there is housing development so no separation with the A46. Therefore in the last 5 years the green belt areas around leamington have vastly shrunk. In a time when we should be focusing on development and protecting the green spaces for biodiversity and for climate change more green spaces are being threatened and are disappearing. We have lots of old brown sites around the town which need to be used rather than left to rot. It may cost a bit more but it is sustainable rather than destructive. We also do not have the resources to service these additional houses, our roads are too busy without any cycle tracks and our schools and doctors over subscribed. I would like to think that my council is more creative with they thoughts of development rather than brutle.

The proposed development at Old Milverton impacts on yet more prime agricultural land which will become more and more precious as our overall population increases There is already a shortage of green belt land and “green lungs” in this area. There is nothing between Jephson Gardens and Newbold Comyn and the land around Old Milverton for residents to be able to exercise and enjoy open countryside. Leamington and Warwick are already known to be among the towns with the highest air pollution in the country. This is a hugely important issue which impacts directly on the health of the local population. Therefore adding more development with attendant traffic increases will add to the problem and stretch it further afield than in the two towns already mentioned. The sewage works in Warwick are already overstretched. Please accept these comments from someone who has lived in this area and has great concerns on the impact of yet more development in this area

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

We are residents living in Wootton Wawen & we feel any further development would be extremely detrimental to the village. We already have major problems with speeding heavy traffic, therefore noise, air pollution & congestion. We have had personal experience with problems of serious flooding and drainage (including sewerage) and any further hard surfaces will only make the problem worse. All facilities are already overstretched, the most obvious example is difficulty accessing local health services. We value our green spaces & access to the country side both for fitness & mental health reasons. The centre of the village has several historic buildings & building the extra houses suggested would seriously restrict our ability to take advantage of the benefits of our local countryside & destroy much of the beauty of the area. We also feel we have been mislead as on the first meeting we were told any building development would be for local people only! We have already been forced to accept major development around the Stratford area which we feel has already destroyed the unique qualities & character of this area. We don’t want to become an urban sprawl. Warwickshire should be recognised & appreciated for its history & the beauty of its countryside. This should be recognised & appreciated especially by our councillors, as this is what attracts tourists & therefore trade into this area in the first place. WE DO NOT WANT OR THINK WE NEED ANY EXTRA HOUSES BUILT AT ALL AS IT WILL ONLY DESTROY OUR VILLAGE & MAKE IT LIKE A SMALL SPRAWLING TOWN.

I would just like to say that Kinetons roads are already overstretched and the bend going into the village is a nightmare. It is not sustainable for more traffic that would go though and out the village for social and work journeys as there is very little social activity in the village and hardly any employment. Would it not best to concentrate on Warwick Stratford and Leamington that have the infrastructure already in place and also the social and work already available.

We would like to submit the following comments with regard to the South Warwickshire Local Plan, in relation to the small village of Bearley. ·The South Warwickshire Local plan concentrates on developing communities which are located near to railway stations. The small village of Bearley does not have a railway station. It has a 'halt' , which is a 'request stop' only. ·There is no parking available at the halt either for vehicles or bicycles. ·There is a single track railway only with very limited services. ·It is not possible to make some return journeys ( e.g. to London) in one day. ·To access work opportunities in the wider area around Stratford upon Avon and the West Midlands , two or more rail journeys are needed , due to the very limited services available at Bearley. ·When working in Edgbaston, Birmingham, my manager looked at the possibility of me travelling to work by public transport, and the bus services were not available to enable me to get there by 07.30 in the morning and to return home at the end of my working day in less than 11 hours of travel. I would have arrived home the next day after I left. ·For residents who live at the far side of the village from the Bearley halt, there would a walk of more than 20 minutes to access these limited rail services. ·For residents who work in the construction and other industries , use of rail services is not possible, since they require a van to transport equipment. ·There is no school in the village , School children have to travel to school in the villages of Snitterfield, Wootton Wawen, Wilmcote , Henley in Arden or Stratford via school buses or be transported by car. The Bearley railway is useless in this regard. ·There is no shop in Bearley, nor any other services such as Doctor, Dental Surgery. ·Until the entire the railway system is more user friendly , people will not use it . ·The local railway services are so poor that even Stratford Parkway Station, despite having large areas for park and ride vehicles and for station parking is grossly underused.

I object to the Wootton Wawen housing development plan. The proposal for 400 homes on green belt in a small village is outrageous! The “village “ feel would be gone forever! The infrastructure is non existent apart from one village shop, two pubs, a train station and school and could NOT support 400 more homes increasing the population by at least 1600?! Green belt should be protected at all costs for the sake of a well balanced environment. The village of Wootton Wawen floods during high river tides. The proposed housing development would add to this issue for many householders. Preventing water draining away quickly, creating more traffic when roads blocked through flooding, and more tensions on the village and disrupting present individual flood defence schemes which have been developed by individuals to protect their properties. It is understood that since writing the plan there has been a shift in the Government’s position. M Gove stated that Green Belt does NOT have to be sacrificed by local plans and should be protected where possible. Consequently there is no longer pressure from the government as there was when the first plans were drawn up. Top down housing figures are often unrealistic … Wootton Wawen’s plan is unrealistic and an abuse of the village way of life. Town and city populations benefit from escaping and enjoying the countryside. It is important that the beautiful English villages are protected for all to enjoy!

The parish council would also like to make several comments/observations: • The justification given in some cases for the blanket approach was that it would make it easier and more predictable for developers. Our view is that this policy document should be in the interests of the people living in those regions, not the developers, • Where is the proof that South Warwickshire require the number of houses quoted including affordable housing? Exactly how many affordable houses are required and where? • It is surprising that ‘Heritage’ is absent from part one of the plan so it is assumed it will be in part 2, particularly in that Warwick District Council (WDC) has so many listed building, designated heritage assets, and conservation areas, • ‘2017, Warwickshire District Council Local Plan identified which polices were considered strategic. 2016 Stratford District Council Core Strategy did not’ – the two district councils are like ‘chalk and cheese’ regarding strategic strategies. There appears to be no hard and fast definition as to what constitutes strategic policy and we feel there should be one, • Page 178 of the document, it is where the two sets of planning policies from the Core Strategy and the Local Plan are listed, and this is where CS8 is ‘Historic Environment – some elements are within part one’: they are not included at all. Even the main regional centres AS1, AS2, AS3 etc. Are all saved for part two and this is worrying. The reality of asking people to merge into one local plan two separate LPA’s that are so far different particularly in their planning policies. At the moment, Warwickshire District Council’s local plan seems to be taking precedence in part one. Disparity between the two and a concern that the approach that Warwick takes has been given greater weight and significance, • Green belt. WDC has an excessive amount of green belt which they protect rigorously and there is also confusion generated between something being washed over by the greenbelt as opposed to being actually in the greenbelt. SDC has very little green belt and it is located in the northwest were it bounds the West Midlands and a small amount by Snitterfield and the north side of Stratford itself. The view that SDC will have about green belt will be completely different to that of WDC which re-emphasises the disparity/incompatibility, • Built Up Area Boundaries (BUAB) is concerning as there is a proposal about changing these. If you are going to preserve a community which is of a manageable sustainable size, there is no logic in changing the boundaries. A change in BUAB would affect all the villages.

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. Sherbourne is identified within Option 5 however growth at these settlements is important in ensuring the future viability and vitality of such settlements. Sherbourne is located south of Warwick and benefits from good transport connections to the strategic road network (M40, A46 and A429). There are opportunities to connect to public transport provision on these routes, notably the A429. Issues S6: A Review of Green Belt boundaries 3.19. 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. 3.20. 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. 3.21. 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. 3.22. 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. 3.23. 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: 3.24. 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. 3.25. 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. 3.26. 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. 3.27. 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? 3.28. 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. 3.29. 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. 3.30. 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 3.31. 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. 3.32. 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. 3.33. In addition, settlement boundaries will need to be reviewed and amended to take account of new allocations.

9. Land East of Vicarage Lane, Sherbourne 9.1. Rainier Developments is promoting land to the east of Vicarage Lane, Sherbourne for residential development. 9.2. The land is currently largely undeveloped and comprised of a large field with an existing building fronting Vicarage Lane. The site is adjoined on three sides by existing residential development. To the north-east, beyond Watery Lane, is agricultural land. 9.3. The site is not located within the Green Belt. The majority of the site is within Flood Zone 1 with a very small area to the far east of the site in Flood Zone 2. The site is adjacent to the Sherbourne Conservation Area and Sherbourne Farmhouse is a Grade II Listed Building opposite the site on Vicarage Lane. The site can be delivered on land within Flood Zone 1 and a carefully designed scheme can be achieved which respects the character of the Conservation Area. 9.4. Sherbourne is currently identified as a Limited Infill Village in the adopted Warwick Local Plan. Limited Infill Villages are identified as having some services and facilities but where limited infill development will help to deliver a choice of housing and support for services in nearby villages. This approach should be reflected in the ‘dispersal’ growth option which, as discussed in previous sections, should form part of the growth strategy for the South Warwickshire Plan to ensure the continued viability and vitality of settlements within the plan area. 9.5. The Site presents the opportunity to consolidate the existing settlement pattern at Sherbourne while meeting housing needs in the area. This would include affordable housing. the site is adjoined on three sides by existing residential development and would read as a logical infill site within the village. 9.6. This is recognised by the 2015 Warwick SHLAA Update (Ref: R197, Land at Black Barn) which states that the site has potential for a small scheme for affordable housing subject to evidence of need and details of the scheme, including a heritage settings assessment. This confirms that the Council consider the site is suitable for residential development. Summary 9.7. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.8. The site is not subject to any designations or constraints that would preclude the development. The Council’s SHLAA stated that the site is suitable for residential development subject to a heritage setting assessment. It is considered that an appropriate design could be achieved on site to deliver a sensitively designed scheme which responds to the character of the Conservation Area. 9.9. The site is well located within the village and is surrounded on three sides by existing residential development. It would read as an infill development and would respect the existing settlement pattern. 9.10. The site is not subject to any statutory nature or heritage designations. Development within the site could be entirely contained within Flood Zone 1 which represents the lowest risk of flooding. The Site could deliver sustainable drainage systems (SuDS) as part of any development. 9.11. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.12. 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. 9.13. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.14. 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. 9.15. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.16. 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.

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. Long Itchington is identified as one of 22 small settlements. It should be noted that the ‘small settlements’ are the only areas assessed at this stage aside from seven broad locations for developments (the largest seven settlements across the Districts) and potential new settlement locations. It should be noted that small settlements are sustainable locations for development. The Site would allow for a sustainable development close to existing services and facilities. 3.18. As set out in the Sustainability Appraisal at Table 5.1, Long Itchington scores similarly to the other small settlements assessed. It is noted that other small settlements score higher than Long Itchington against Education and Accessibility. This is discussed in more detail in following sections however Long Itchington has a primary school, is located within the target distance for further education and would be able to access the existing secondary school in Southam via public transport or a short dedicated bus route. It should also be noted that the SA at this stage does not consider any mitigation. Growth at Long Itchington would assist in supporting and likely enhancing the existing public transport provision which would mitigate any accessibility concerns. 3.19. It is clear that this Site (Call for Sites ref: 462) is located in a sustainable location and should be positively considered as a location for growth. Issues S6: A Review of Green Belt boundaries 3.21. 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 development boundary for Long Itchington should be reviewed which would allow for the inclusion of this Site (Call for Sites ref: 462) within the development boundary for this settlement to deliver sustainable residential growth.

9. Land North of Leamington Road, Long Itchington 9.1. Rainier Developments is promoting land north of Leamington Road (West), Long Itchington for residential development, inclusive of on-site green infrastructure. 9.2. The land comprises a single agricultural field. The northern, eastern and southern boundaries are defined by existing boundary vegetation and the western boundary adjoins an existing access track. The site is north of Leamington Road, the south of this road is characterised by residential development. To the east of the site, land north of Leamington Road is characterised by existing residential development. A site location plan is enclosed at Appendix 1. 9.3. The site is immediately adjacent to the village and would benefit from good access to local services and facilities including, for example, the Cooperative food store, various pubs, bus stops and the church. 9.4. The accompanying Illustrative Masterplan (see Appendix 3) shows how the site could be developed to deliver circa 60 dwellings. The built development would be concentrated towards the southern and central parts of the site, closer to Leamington Road. This would allow for a significant area of landscaping along the sites northern boundary. The Masterplan also demonstrates how the site could link to the adjacent site to the east which has also previously been promoted through the Site Allocations Plan. Rainier’s position that the sites could come forward either independently or in tandem as a coherent scheme remains unchanged. Sustainability Appraisal SA 9.5. This site is located in Long Itchington which is identified as a small settlement within the SA. The site lies within the area assessed around Long Itchington as shown at Figure C14.1. It is evident from this plan that the site is not subject to any overriding constraints. The site would form a logical extension to the existing settlement and would reflect the character of settlement which is effectively two broadly linear patterns of development either side of the A423. 9.6. The assessment of Long Itchington against the SA objectives is presented at Section C14.1 of Appendix C. It is acknowledged that, at this stage, the assessment covers a wide area and the ratings will not be applicable to each individual site. Each SA Objective is considered with specific reference to the site below: 9.7. SA Objective 1 Climate Change: The site is proposed for residential development and is in a small settlement identified within Growth Options 3, 4 and 5. The Site would benefit from good access to local services and facilities, reducing the need to travel to meet everyday needs which is reflective of the aspiration to deliver 20-minute neighbourhoods. 9.8. SA Objective 2 Flood Risk: The site is entirely within Flood Zone 1, land at lowest risk of flooding. There are elements of surface water flood risk along the sites eastern boundary, this could be addressed through suitable design and sustainable drainage systems. 9.9. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: The site is not designated as or in close proximity of a Special Conservation Area (SAC), Site of Special Scientific Interest (SSSI), National Nature Reserve (NNR), ancient woodland, Local Nature Reserve, Local Wildlife Site, Local Green Space (LGS) or priority habitat. The SA notes the proximity of Debdale Wood and Spinney Ancient Woodland as a potential negative impact in the absence of any mitigation. This site is not within the 15m buffer requirement for ancient woodland and is some 1.3km away. The closest local wildlife site is to the north of the recreation ground and is well separated from the site. The majority of the local wildlife sites and priority habitats in Long Itchington are to the east and south of the settlement. 9.10. SA Objective 4 Landscape: Previous assessments prepared in support of the Stratford Site Allocation Plan have noted that the southern portion of the adjacent site (to the east) was considered deliverable and that suitable landscape and visual mitigation could be achieved. Rainier have made previous representations to this document and accompanying assessments that the same would be applicable to this Site and are confident that appropriate mitigation could be achieved. A Landscape Note (enclosed at Appendix 4) confirms that a scheme on this Site could incorporate an appropriate and robust strategy for landscape mitigation. 9.11. SA Objective 5 Cultural Heritage: The site is not located in proximity to any designated heritage assets. The majority of listed buildings in Long Itchington are located to the south, around Church Road. This is also the focus of the Conservation Area which includes part of Leamington Road, to the east of Chaters Orchard. The site is well separated from the designated assets and the CA by existing built development. 9.12. SA Objective 6 Pollution: The site is not located in proximity to an Air Quality Management Area. The A423 which bisects the settlement, running north/south generally through the middle of the village, is identified by the SA as the main pollution source. The site is well separated from the A423, including by existing development, and any associated noise and air quality mitigation required could reasonably be expected to be minimal. 9.13. SA Objective 7 Natural Resources: It is acknowledged that the land at Long Itchington is a mixture of Grade 2 and Grade 3 agricultural land. However, the site is reasonably smallscale compared to the wider agricultural land in this area and the loss of agricultural land associated with this site is not anticipated to be significant when considered in the wider context. The entire settlement is within a Mineral Safeguarding Area (MSA). In common with the agricultural land, the development of this site is not significant given the scale of the MSA. It is also notable that the site is immediately adjacent to existing residential development on Leamington Road and therefore is unlikely to be suitable to mineral extraction given the associated impact on residential amenity. 9.14. SA Objective 8 Waste: A residential development would generate a level of household waste however this can be managed with provision of suitable recycling facilities for all households. 9.15. SA Objective 9 Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing. 9.16. SA Objective 10 Health: The site benefits from good access to existing recreation and greenspace within the village. The closest health facilities are in Southam, which is accessible by an existing bus service. 9.17. SA Objective 11 Accessibility and 12 Education: The site benefits from existing bus stops which provide a regular service to Southam, Napton on the Hill and Leamington Spa. It is important to note that development in settlements such as Long Itchington is important in supporting the ongoing viability of existing services and securing improvements. The village has a primary school, located on Stockton Road, with secondary and further education facilities located in Southam which is accessible by bus. 9.18. SA Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities in the local area. Summary 9.19. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.20. The site benefits from a sustainable location on the edge of Long Itchington and is well placed to meet the housing needs of the village and the surrounding area. The site is wellplaced to ensure easy access to a range of local services and facilities including public transport. 9.21. 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. 9.22. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.23. 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. 9.24. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.25. 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. 9.26. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.27. 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.

As the civic society for the town of Stratford-upon-Avon, the Stratford Society aims to protect the heritage of our historic market town, and to support development which maintains its health and prosperity for the benefit of those in South Warwickshire who live in and around it. We believe that its economic wellbeing depends on a combination of respect for the past and appropriate development to meet the needs of the future. The Society was closely involved with the development of the town’s Neighbourhood Development Plan 2021-2031, approved in a referendum of voters in November 2018, and continues to seek its implementation. Since the current Consultation extends beyond the town of Stratford-upon-Avon, the Society is confining its response to its three principal areas of interest – heritage, transport and planning. In so far as they relate to the town of Stratford-upon-Avon, the Society supports the Vision and Strategic Objectives set out in the Consultation document. In particular, it wishes to ensure environmental resilience in terms of air quality and flood prevention for the health and safety of the town’s residents and visitors. It is crucial that this is addressed to tackle the current climate change emergency. Similarly, the Society supports the vision for a well-designed and beautiful South Warwickshire in which the town has a key role to play. It agrees that heritage and cultural assets have a significant impact on a sense of place and the character of the area. It is the very nature of Stratford-upon-Avon, in terms of its Heritage assets and open spaces, that encourage people to want to live there or come to the town as visitors. Contrary to the implication in the Consultation document, this appeal is not confined to Shakespeare’s Birthplace and the RSC. Rather it is the historic appeal of the many old buildings along the Historic Spine between the Birthplace and Holy Trinity Church, and the delightful aspect of its riverside setting, offering peace and tranquillity. This is beneficial to the physical and mental health of residents and visitors alike. At all costs, this must be safeguarded, while not forgetting that it also brings economic benefits to the town’s hotels, restaurants and shops. A glaring omission from the Vision and Strategic Objectives is any reference to the creation of employment opportunities leading to economic development. The reality is that, given its central location and good connectivity to the wider West Midlands and beyond, South Warwickshire has the potential to become one of the drivers of the regional economy. In posing questions about the quantity of new development and where it should go, the Consultation document focuses on housing to the exclusion of other key issues. Without growth in employment, any expansion of housing in Stratford-upon-Avon and the surrounding neighbourhoods would mean these becoming no more than dormitory towns with their residents having to travel outside the area to cities such as Birmingham and Coventry to find work. This would sound a death-knell to the economy and wellbeing of Stratford-upon-Avon and the wider county unless an Employment Plan is created to encourage businesses and organisations to establish themselves in South Warwickshire. Furthermore, the Stratford Society is concerned that, without the creation of new employment opportunities, further house-building south of the river would exacerbate existing problems with congestion and pollution in Stratford-upon-Avon. Given the limited number of crossings over the River Avon, there is the likelihood of an ever-increasing number of vehicles, including HGVs, being funnelled across Clopton Bridge. This ancient, Grade 1-listed structure is already the cause of major bottlenecks for traffic travelling into the town from south of the river, leading to diminishing air quality as fumes are emitted from vehicles at a virtual standstill. The switch to electric vehicles will not come quickly enough to eliminate this hazard to the health of Stratford’s residents and commuters alike. If passengers and freight are to be taken off the road network, the development of better public transport links and cycle paths are vital. Any new settlements need to be located near existing – and, preferably, expanding - rail corridors, and bus services to and from rural areas should be greatly extended to get private vehicles off the road. Here, the Society agrees with the Stratford-upon-Avon Town Transport Group that a Transport Plan should be a key element of any proposals for future development. Furthermore, to support any new development in South Warwickshire, an Infrastructure Plan needs to be developed and, very importantly, delivered in a timely manner before residents move in. This should include the provision of schools and medical facilities which match the level of growth. It is a given that these should be built to the highest environmental standards, using green energy. Without such facilities, together with employment opportunities and transport links, the idea of creating 20-minute neighbourhoods falls flat. In conclusion, there are key issues to be addressed before options for the extent of further housing, and where it should go, can be properly assessed. Only then can consideration of the need for more development be balanced against the impact on the built and natural environment of South Warwickshire.

Although I would not be so dogmatic as to oppose the loss of greenbelt land for residential and commercial purposes in absolutely any context this should only be undertaken in exceptional circumstances, as the National Framework requires. The local plan suggests the erosion of the greenbelt in North Leamington, both in developments impinging on Old Milverton and Blackdown. The former would lead to the further erosion of vitally required own space while the latter would seriously erode the green space between Leamington and Kenilworth. Moreover the local plan does not make it clear what its view of the current green belt is and how this could/should be eroded with reasons for this. What are the current criteria which Warwick District Council follows? The Green Belt in North Leamington is of particular importance both in preserving the separate characters of Leamington and Kenilworth and in enabling leisure pursuits such as walking, including dog walking, running and cycling for local residents. There is only a limited open publicly accessible space in this part of Leamington and the proposals in the local plan could greatly reduce this. • These proposals will very significantly accelerate a drift towards urban sprawl and is therefore in contravention of the principles of the National Planning Framework. This rejects proposals urban sprawl and certainly is not justified by any exceptional circumstances. These proposals in the local plan therefore go against the whole principle of the Green Belt as developed since the 1940s. • Meeting the increased traffic near to the line of the A 452 and A46, to which new development, for example 231 and 211 could contribute, will simply further accelerate the erosion of the Green Belt between Leamington and Kenilworth, in addition to the new housing... It could also threaten the surviving rural character of Old Milverton. This would over a relatively short time lead to Leamington, Old Milverton and Black down joining up with Kenilworth a very large conurbation • We already have Leamington and Warwick running into each other with all the attendant traffic problems, deriving from a time before proper planning was in place. With hindsight this ought to have been avoided. With future sight we must not let this happen in north and central Leamington. • the assessment of sites in Appendix 3 implies that the proposals of Old Milverton and Blackdown would not lead to joining together of the settlements . This is a poorly based judgment. • Although these are only proposal at this stage development on sites 531 and 174 would significantly erode the Greenbelt which is surely meant to prevent this kind of coalescence. • There should certainly be a review of issue S6 of the Greenbelt , particularity its scope. High Quality Farmland Old Milverton and Blackdown have high quality farmland,. It is vital to safeguard this, not least in the highly unstable global situation and the problems for food supplies. Note that while public footpaths related to leisure crossing farmland in Old Milverton does not degrade the value of this land as farmland and farmers ‘notices on the fields are careful to alert the public to this • Other Possible Housing Development How much extra housing is really required depends upon assumptions and projections based upon census and other data. In the current difficult economic climate, likely to be sustained over a long period, it is very difficult to anticipate what the demand will be but surely unlikely to equal the recent past. And if part of the argument is to meet Coventry's housing needs it is surely sensible to locate very near to Coventry, to minimise commuting pressures. • The Leamington Community It is very important to stress that this is not simply a matter of people in North Leamington preferring development in South Leamington and vice versa. The increased traffic flows through the central area which development in the north – at least on the scale proposed – would affect all Leamington residents and detract from the amenity of all residents. It would also reduce the leisure opportunities available to some Warwick residents coming into the Old Milverton area.. Appreciating the pressure on the district council's local plan there may be scope for some modest infilling development perhaps brownfield site in North Leamington which would not threaten the erosion of the Green Belt in any significant way. It is the scale of the proposed development in north Leamington and the associated infrastructure needs which are so significant. This will send us on the high road to the merging of the Leamington and Kenilworth areas with further degradation of local leisure amenities and wildlife.

Q-S5.2: Do you think new settlements should be part of the overall strategy? Yes - The Joint Local Plan should consider potential new settlement locations as part of a broad strategy of growth across the Plan area. New settlements can assist in the delivery strategic infrastructure which have a positive have a social, economic and environmental impact. Option F2 provides the opportunity for a new settlement in an area broadly to the southwest of Southam and within proximity of the settlements of Harbury and Bishops Itchington. Land at Deppers Bridge (see Site Concept Plan at Appendix 1) could deliver development in this area that would assist in the delivery of key infrastructure within the site creating a New Settlement. This includes the provision of a railway station on the existing Chiltern Line, a link road, diverting traffic around Bishops Itchington and provide the necessary social, health and education infrastructure (in the form of new primary and secondary schools) within the site.New settlements provide the opportunity to deliver infrastructure at scale, provide new services and facilities and in doing so help to create more sustainable communities. They can do this in a way which is not achievable through reliance solely on a strategy of dispersal, where the necessary critical mass of population and funding can be secured to support such strategic level investment. Additionally, the provision of new transport infrastructure, such as a railway station, may also lead to an enhancement of the levels of sustainable access to key services and facilities for hinterland rural communities. Rural villages and settlements, where there is a lack of walking, cycling and public transport connections and where small or medium-scale growth is unlikely to improve provision of key services and facilities or transport infrastructure, it might not be appropriate, for sustainability reasons, to consider growth through the Local Plan. This is of particular relevance to the plan area of South Warwickshire which has historically comprised of dispersed rural settlements. Moreover, in the SA considerations of proposed new settlement areas the F2 location performs the same as all other current options, with the exception of flood risk and landscape matters which it is acknowledged within the SA these issues could be mitigated. Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire. The 5 no. spatial options for growth set out in the Issues and Options document have been refined from the 7 no, presented in the 2021 Scoping and Call for Sites consultation. The Councils’ Topis Paper ‘Evolving the Spatial Growth Options – the Story so Far’ notes that no one option presented at the previous stages of the Plan was overwhelmingly preferred. Of the options now presented in the Issues and Options, apart from Option 5: Dispersed, the other four options perform broadly similarly to each other in the SA (Table 7.1) suggesting no one option may have significantly more or less impact than any of the others when considered against the SA Framework. 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. However, as the emerging evidence demonstrates, in order to provide necessary levels of infrastructure within the two districts, there will be a need for a new settlement to assist in the delivery of housing and strategic infrastructure within the plan period. The Plan area has a current pattern of development that varies across its two administrative areas. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a significant proportion of development. By necessity, the future development strategy for the plan area 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. Commentary on Options 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, such as through the allocation of new settlements, will therefore be required and it is important that all options are considered in taking the Plan forward. The Strategy may need to facilitate a combination of the 5 no. options presented, where different growth options should be tested as part of the ongoing Local Plan preparation and SA process to ensure all reasonable alternatives are considered. This will require a careful consideration of all of the options, including growth at existing main settlements, some growth at new settlement locations/s on the rail lines, growth at smaller existing settlements, proximity to services and jobs, and availability of infrastructure or opportunities for infrastructure delivery. Q-S9: Please select the option which is most appropriate for South Warwickshire Option There will be a need to maintain established settlement boundaries identified within the currently adopted local plans as a minimum to accommodate development that is of an appropriate and sustainable scale in relation to these settlements, where appropriate within the plan period. It is considered that a combination of both options may be appropriate for the Joint Local Plan. Where the Plan seeks to allocate land for development for strategic sites as set out at paragraph 1.4 of the Issues and Options document, then reviewing settlement boundaries should be undertaken as part of the proposed site allocation. Beyond this, to be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. It is considered that a review of settlement boundaries may be an appropriate approachfor the Joint Local Plan. Where the Plan seeks to allocate land for development, especially when considering the provision of a strategic new settlement, it would be necessary to undertake a review of settlement boundaries as part of the proposed site allocation. For example, land at Deppers Bridge plus the existing settlements to the northwest and south could potentially be defined by a settlement boundary which relates to their strategic function in delivering growth and development. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire It is noted that within Figure 12 of the Issues and Options document that New Settlement Potential Location A1 is labelled as Henley in Arden. However, when reviewing the locationof the proposed allocation area it is apparent that the proposed allocation is sited closer to the existing settlement Tanworth in Arden and therefore lacks clarity in respect of the location of this new settlement proposal. The assessment of site A1 within Appendix D of the Sustainability Appraisal, specifically Figure D.2.1 demonstrates that the general area for the proposed allocation is located to the west of Tanworth in Arden. Therefore, we would advise that going forward this allocation proposal is renamed to reflect its accurate geographic location within South Warwickshire.

Q-S4: YES. The overall development strategy should include delivery of sustainable development across South Warwickshire’s existing settlements as part of its overall strategy and plan. This being particularly pertinent where any proposed development would meet the needs of the local community. Paragraph 79 of the NPPF (2021) is clear that planning policies should ‘identify opportunities for villages to grow and thrive’. Continued use of a settlement hierarchy should be supported to ensure development is directed towards the most sustainable towns and villages and where this supports a level of growth aligned with the settlement’s relative sustainability. The adopted strategy inclusive of expansion to existing settlements ought to be based on a robust series of evidential hierarchy considering both housing and employment needs to meet the requisite tests of soundness within the NPPF (2021) paragraph 35.

1-The land (WK370607, edged yellow) being considered for release from green belt is subject to a restrictive covenant (contained in a conveyance of 1893) which prohibits the development of residential housing on it. This was put in place to protect the amenity of this land to local properties, which have the charge recorded on their respective titles. Such covenants run with the land (rather than the various historic freeholders at the time). Any allocation of this land would therefore seem ultra vires as it could not come forward as a development site to meet any housing needs; a material factor when considering allocations. 2-The swlp should fully examine all other options, including new settlement options outside of the green belt, before starting a study to review green belt boundaries in South Warwickshire. 3- An area should maintain its green belt status if it meets any one of the five purposes of green belt, as defined in the NPPF.

North Leamington Green Belt. The population of the UK is continuing to grow and housing is urgently needed and it is important that Leamington Spa continues to help to provide this accommodation and important economic growth. Looking at a local map showing the green belt its expansion makes more sense by being stretched to the south of the town with Stratford upon Avon, Southam and Banbury being a distance away, with local development boundaries maxed to the Banbury Road, Fosse Way and M40. If we are serious about maintaining a green belt, a nature passage, and to avoid a future urban sprawl, then the green belt to the north of Leamington Spa should be maintained. It is already close to Leek Wooton, Stoneleigh and Kenilworth and it's only the river Avon boundary that separates us from Warwick. Nature does not have a voice on this issue and it's up to us to speak up and to use our common sense and protect it for future generations enjoyment.

Having seen the proposed plans for areas B5, B6, B7 and B10, I am horrified at the proposals that these should be considered for development. Building in these areas will destroy Kenilworth as a town surrounded by fields, and the link to Coventry will be almost complete. During lockdown many people visited Kenilworth to walk and exercise in the country and now your consultants consider these areas fit for development. There are no shops within a 15 walk from most of the proposed areas, no doctor or dentist facility. The primary schools are already full, nursery facilities are limited. Road issue exist already with speeding motorists regularly breaking the speed limits. Bus transport is very limited. In all ink the proposals appear to have been drafted by someone using a map rather that trying to appreciate what exists as a benefit to current residents. I believe building large numbers of houses in the designated areas is not required and I would suggest that there should be a re-think of where to build, possibly apartments on brown field sites would be a better alternative.

Stockton Parish Council wishes to comment as follows on the SWLP draft. As a village it was classed as a Category 2 Local Service Village in the Core Strategy with an allocation of new housing that has been exceeded with 111 times built in the period 2011-2022. Due to the timings of permissions that were granted before the Core Strategy was adopted virtually no CIL payment were made by the developers that ended up benefitting the community. In fact only two small payments totalling approximately £5,000 in respect of individual houses have accrued. During this period approximately 250 extra inhabitants have been added to the parish population but no resources were made available to improve infrastructure such as the village hall, sports and play facilities for adults and children, water supply and drainage, sewers, road safety, public transport, etc. It is believed that extra staff were recruited at Stockton Primary School, presumably through the “per capita” allowance. Fortunately the Parish Council is able to say that the increase in population has been successfully assimilated into parish life and has probably strengthened community activity with fresh blood. The view of the parish community and the parish council up until now has been to resist any further developments of more that the odd home. However, with the current shortage of new homes leading to higher prices that preclude less well-off families or first time buyers, that parish council believes it is now opportune to revisit that view, particularly in the light of the Housing Needs Survey carried out by WRCC in July 2021. The council would be prepared to support new developments subject to the following conditions:- a maximum of 100 properties over the plan period to 2050 with developments spread over a wide timeframe to avoid a sudden large influx of new villagers. a proportion of 35% of these to be affordable homes for rent or shared ownership. significant resources being made available to improve village facilities such as the village hall, an updated children’s playing field, a bus turnaround island off Napton Road that would move the bus route from the congestion on Post Office Lane and High Street. suitable improvements to local infrastructure such as water, drainage, sewage, public transport.