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

EXECUTIVE SUMMARY 1.1 These representations have been prepared by Boyer on behalf of Kingacre Estates Ltd (‘Kingacre’), in response to the Regulation 18 ‘Issues and Options’ consultation, prepared by Stratford-on-Avon District Council (‘SADC’) and Warwick District Council (‘WDC’) (‘the Councils’) for the emerging South Warwickshire Local Plan Part 1 (‘SWLP’). 1.2 Kingacre hold a specific land interest within Stratford-on-Avon District, known as the Land Adjacent to Grange Cottages, Hardwick Road (‘the site’). The site has previously been assessed in SADC’ Strategic Land Availability Assessment (‘SLAA’) under SLAA reference PM.08. These representations are aligned with this land interest and address topics within the SWLP consultation, and its supporting evidence base, accordingly. 1.3 The purpose of these representations is to assist the Councils in formulating an approach within the emerging SWLP plan-making process that is both consistent with national planning policy and the tests of soundness. 1.4 General support is provided to the overall objectives identified in the SWLP and detailed commentary is provided in relation to the appropriate Spatial Strategy for the District. However, it is considered that there are several flaws and omissions within the SWLP and its evidence-base at this stage, which are detailed within these representations. 1.5 The SWLP Issues and Options consultation proposes that the emerging plan should meet, as a minimum, the identified housing need arising within the plan’s area. Furthermore, the Plan affirms the duty of the Districts to meet a proportion of the residual unmet housing need arising from nearby authorities; in particular, need arising from within the Greater Birmingham & the Black Country HMA and the Coventry & Warwickshire HMA. 1.6 Significantly, the SWLP proposes departure from the Government’s prescribed Standard Methodology, replacing the 2014-based household projections with trend-based projections utilising up-to-date data from the 2021 Census. Consequently, both districts’ annual Local Housing Need figure increases markedly, reflecting demographic trends over the last decade. 1.7 Kingacre supports the Councils approach. Kingacre considers that the assessment of Local Housing Need detailed within the SWLP, based on the Councils’ Housing and Economic Development Needs Assessment (‘HEDNA’) (2022), adequately reflects current and future demographic trends and market signals, which should therefore be considered a sound approach as set out in planning practice guidance1 . 1.8 Furthermore, Kingacre supports the Councils’ commitment to accommodate the identified local housing need for the Districts in full, in addition to an appropriate amount of unmet need arising from nearby authorities in accordance with the Duty-to-Cooperate (‘DtC’). Such an approach would maintain the existing commitment, made in both SADC’s and WDC’s current adopted district plans, and would support housing delivery in the wider region in accordance with the Government’s commitment to significantly boost the supply of housing, ensuring minimum housing needs are met. 1.10 Notwithstanding the five Spatial Strategy Options identified in the SWLP, the Councils’ evidence-base identifies limited further growth potential in the most sustainable urban areas of South Warwickshire: Leamington Spa, Stratford-on-Avon, and Warwick, alongside the settlements covered by the West Midlands Green Belt and the Cotswolds National Landscape AONB. 1.11 To assist in meeting the District’s significant housing need, we recommend the allocation of Land Adjacent to Grange Cottages, Hardwick Road, Priors Marston (‘the site’) for up to 25 new homes within the emerging SWLP. The relatively unconstrained nature of the District’s central and eastern areas, in combination with the series of Local Service Villages, provides that these areas remain appropriate to accommodate a significant proportion of the identified housing need. The land at Priors Marston is available and well-placed to make a modest though nonetheless valuable contribution toward this. 1.12 To support the vitality of the Districts’ villages, including Priors Marston, and deliver muchneeded affordable housing in rural areas, it is crucial that the Councils support the sustainable growth of these areas and the villages. 1.13 To this end, Kingacre supports the identification of Spatial Strategy Option 5: Dispersed Approach as a suitable spatial strategy for South Warwickshire. Priors Marston comprises an unconstrained settlement that can accommodate sustainable growth during the plan period. The Land Adjacent to Grange Cottages, Hardwick Road, is well-positioned to make a valuable contribution to meeting the District’s development needs and support the delivery of much needed new market and affordable homes. 1.14 The Site is in a sustainable location, within practical walking and cycling distance of the range of services and facilities provided in the Village, and benefits from good access to nearby main settlements including Daventry and Leamington Spa. There are no significant constraints to the development of the Site which could not be effectively mitigated, meaning the site is capable of providing up to 25 high-quality new homes. 1.15 Kingacre confirm the Site is available for development immediately. The Site comprises a suitable location for development, current Development Plan constraints aside, and is achievable for the type of development proposed, providing a realistic prospect that 25 new homes (comprising market and affordable) can be delivered within the first five years of the emerging plan period. 1.16 Accordingly, Kingacre promote the allocation of the site for approximately 25 new homes in the emerging South Warwickshire Local Plan. INTRODUCTION 2.1 This representation is made by Boyer, on behalf of Kingacre Estates Ltd (‘Kingacre’) to act on their behalf in respect of the ongoing promotion of Land Adjacent to Grange Cottages, Hardwick Road (‘the site’) for residential development. A Site Location Plan is provided at Appendix 1. 2.2 These representations relate to the tests of soundness set out at paragraph 35 of the NPPF; namely, whether the emerging South Warwickshire Local Plan (‘SWLP’) is: a) Positively prepared – providing a strategy which as a minimum seeks to meet the area’s objectively assessed needs. b) Justified – provides an appropriate strategy, taking into account reasonable alternatives and based on proportionate evidence. c) Effective – deliverable over the plan period and based on effective joint working. d) Consistent with national policy – enabling the delivery of sustainable development. 2.3 At this early stage of plan-making, it is important that Stratford-on-Avon and Warwick District Councils (‘the Councils’) pursue an approach that is consistent with national policy, effective, justified, and positively prepared. These representations comprise our recommendations to assist the Council in achieving such an approach as emerging plan progresses toward adoption. 2.4 This representation should be considered in combination with previous representations submitted to Stratford-on-Avon District Council by Kingacre in relation to the ‘Site Allocations Plan Regulation 18 Revised Preferred Options’ consultation, which ran from 16 June to 29 July 2022, and the ‘SAP Regulation 18 Preferred Options’ consultation, undertaken in late 2020. Policy Context 2.5 Stratford-on-Avon District Council (‘SADC’) adopted the Core Strategy (2011 – 2031) on 11 July 2016 and Warwick District Council (‘WDC’) adopted the Local Plan (2011 – 2029) in September 2017. Together, the adopted plans set out the spatial strategy to meet development needs across South Warwickshire District up to 2029 and 2031 respectively. 2.6 The Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended) requires local planning authorities to review local plans at least once every 5 years from their adoption date. This is intended to ensure that planning policies remain relevant and able to effectively meet the needs of the local community. The SWLP, which is the subject of this Regulation 18 consultation, represents the outcome of these review processes; with SADC and WDC committing to working together to prepare a new local plan for the broader South Warwickshire area. The Issues and Options plan sets out a broad vision for South Warwickshire up to 2050, identifies the various issues associated with achieving this vision, and outlines several options to address each of those issues, including the overall strategy for the pattern, scale, and design quality of places within South Warwickshire. 2.8 Kingacre supports the Councils’ commitment to prepare a new Local Plan for the South Warwickshire area. Land Adjacent to Grange Cottages, Hardwick Road, Priors Marston 2.9 Land Adjacent to Grange Cottages, Hardwick Road, Priors Marston (‘the site’) comprises approximately 1.8 hectares of land toward the southern edge of Priors Marston village. The site lies to the south of Hardwick Road and to the west of Byfield Road, within the parish of Priors Marston. The site currently comprises an open field, bordered by dense hedgerows with some intermittent tree cover, wrapping around a small collection of dwellings (including Grange Cottages) to the north. 2.10 Stratford-on-Avon District Council assessed the site as part of the Strategic Housing and Economic Land Availability Assessment (2020) (‘SHELAA’) process, under Site ID number PM.08. The site is determined by the Council to be available for development, in accordance with the NPPF and Planning Practice Guidance (PPG). 2.11 However, conclusions have been arrived at that the site is neither suitable nor achievable for development at this time. Kingacre strongly disagree with the conclusion that the site is neither achievable nor environmentally suitable for development within the plan period. In Section 6 of these representations, the site is demonstrated to not only be both suitable and achievable for development, but preferable to alternative potential site options already considered by SADC at the Village. 2.12 The site is within a sustainable location and there are not considered to be any significant constraints to development of the site for residential dwellings within the plan period. The proposed development of up to 25 new homes would contribute toward the Districts significant identified housing need, in addition to providing a range of further benefits: including much-needed affordable housing, biodiversity improvements, and improvements to local community facilities. 2.13 The site is available for development now, offers a suitable location for development, and is achievable with a realistic prospect that housing can be delivered within the next five years. As such, the site should be considered favourably under the terms of the NPPF and consequently allocated for residential development in the emerging South Warwickshire Local Plan. CONCLUSION 7.1 The draft South Warwickshire Local Plan sets out how Stratford-on-Avon and Warwick District Councils propose to, as a minimum, meet identified local housing needs arising within the South Warwickshire Plan area. Furthermore, the Plan affirms the duty of the Districts to meet a proportion of the residual unmet housing need arising from nearby authorities; in particular, need arising from within the Greater Birmingham & the Black Country HMA and the Coventry & Warwickshire HMA. Kingacre fully supports this positive and proactive approach being taken by the Councils 7.2 Significantly, the SWLP proposes departure from the Government’s prescribed Standard Methodology, replacing the 2014-based household projections with trend-based projections utilising up-to-date data from the 2021 Census. 7.3 Kingacre supports this approach and supports the Councils’ commitment to accommodate housing needs in fully. This would maintain the commitment made within the adopted spatial strategies of each district and would support housing delivery in the wider region in accordance with the Government’s commitment to significantly boost the supply of housing. 7.4 The Issues and Options consultation presents five reasonable alternative Spatial Growth Options which could be implemented to direct new development within South Warwickshire over the plan period. Notwithstanding the problematic evidence-base supporting the assessment of these alternative Spatial Growth Options, Kingacre welcomes the identification of Spatial Growth Option 5 – Dispersed and recommends that, given further work to refine the option, it could represent an appropriate spatial strategy for South Warwickshire of itself. Or as a component part of any other overarching strategy taken to ensure the towns and villages across the SW area are supported, and sustainable planned growth is facilitated over the plan period – including delivery of much needed affordable homes. 7.5 The relatively unconstrained nature of South Warwickshire’s central and eastern areas, in combination with the presence of a series of sustainable, small-and-medium sized villages, provides that the area remains appropriate and capable of accommodating a significant proportion of the identified housing needs. 7.6 To this end, Kingacre recommends the identification of the Land Adjacent to Grange Cottages, Hardwick Road, Priors Marston, as being suitable for allocation within the next iteration of the SWLP, as part of any appropriate spatial strategy for the SW area. Priors Marston comprises an unconstrained settlement that could accommodate a reasonable level of growth during the plan period. The Land Adjacent to Grange Cottages, Hardwick Road, is well-positioned to make a very reasonable contribution to meeting development needs. The site is in a sustainable location, within practical walking and cycling distance of the range of services and facilities provided in the Village. The site benefits from good access to nearby main settlement areas, including Daventry and Leamington Spa, and good access to mainline train services at Banbury and Leamington Spa. There are no significant constraints to the development of the site, which could provide up to 25 high-quality new homes. 7.8 On behalf of our client, we can confirm the site is available for development now, represents a suitable location for development, and that development of the site is achievable with a realistic prospect that housing can be delivered within the first five years of the draft plan period. The site is deliverable and should be favourably considered for allocation in the next iteration of the SWLP. 7.9 We look forward to continuing to work with Stratford-on-Avon and Warwick District Councils, Priors Marston Parish Council, and the village’s community to provide much-needed new housing. 7.10 We hope these representations are of assistance in taking the plan forward. Should you require any further clarification on the issues raised in our comments please contact me.

Q-S4.1: + Q-S4.2: The NPPF8 requires that strategic policies should set out an overall strategy for the pattern, scale, and design quality of places, making sufficient provision for housing and other development needs. Kingacre welcomes the Councils’ consideration of several alternative options for an appropriate spatial strategy for South Warwickshire up to 2050. 4.2 The Issues and Options consultation presents five alternative spatial options, which are evaluated within the Sustainability Appraisal prepared to support the plan. A further two ‘hybrid’ options are discussed within the Plan. The five alternative spatial options discussed within the SWLP comprise: • Option 1: Rail Corridors • Option 2: Sustainable Travel • Option 3: Economy • Option 4: Sustainable Travel and Economy • Option 5: Dispersed 4.3 Notably, the Issues and Options consultation (alongside the Sustainability Appraisal) consider the five alternative spatial options within a ‘Policy Off’ approach. This approach is problematic, as it is not possible to assess the deliverability of the various spatial options, as the availability, suitability, and achievability of the identified potential development locations has not been confirmed. 4.4 Furthermore, the alternative spatial options have not been assessed in accordance with their potential relationship with important planning designations, such as the West Midlands Green Belt and the Cotswolds National Landscape Area of Outstanding Natural Beauty (‘AONB’). Considering the protection afforded to each of these designated areas within the NPPF9 , notwithstanding adopted policy within the SW area, this is considered to be a serious limitation in the analysis which needs to be revisited. 4.5 Notwithstanding these limitations, Kingacre welcomes the identification of Spatial Strategy Option 5 – Dispersed. It is considered that, once further work has been undertaken to refine this general spatial strategy option, it would represent a suitable basis for the distribution of development within South Warwickshire up to 2050. The benefits of the approach are set out below, but comprise four core themes: • Lack of exceptional circumstances to justify release of land from the Green Belt, • Protection of the Cotswolds National Landscape AONB, • The availability and suitability of land within the SW area for development, and • Supporting the Viability and Vitality of the Rural Communities. The SWLP identifies that South Warwickshire demonstrates an historically dispersed settlement pattern and is home to a significant number of existing settlements of varying sizes. Recognising this dispersed settlement pattern, particularly within Stratford-on-Avon, the District’s adopted Core Strategy (2011 – 2031) implements a spatial strategy ‘...based on a pattern of balanced dispersal, in accordance with the distinctive character and function of the wide range of sustainable locations across the District’ 10 . 4.7 Furthermore, the emerging Site Allocations Plan (‘SAP’) for the District commits to implementing ‘...the basis of the distribution of development established in Policy CS.15 of the Core Strategy’. Kingacre welcomes the Council’s recognition that an appropriate spatial strategy for the SW area should continue to implement the ‘pattern of balanced dispersal’ set out within Policy CS.15 (Distribution of Development) of the adopted Core Strategy. 4.8 Together, the adopted spatial strategies for Stratford-on-Avon and Warwick Districts direct development toward the most sustainable settlements, whilst recognising the limited capacity of the main settlements to accommodate the full housing and economic needs of the area. Kingacre welcomes this approach and recommends that the Councils’ continue to implement a spatial strategy for South Warwickshire based on this sustainable and dispersed approach. 4.9 The Councils’ Urban Capacity Study (2022) affirms that South Warwickshire is reliant on the development of greenfield land to meet its housing needs; noting: ‘...the study has established that it is unlikely to be possible to meet currently development needs without significant greenfield development’ 11 . 4.10 Given the extent of the existing committed development within South Warwickshire (which includes both permitted and allocated development sites), much of which was directed to the most sustainable locations through the adopted spatial strategies, it is clear that there is limited further capacity for development within the most sustainable locations in the area. 4.11 The Urban Capacity Study (2022) identifies that, of the 30,750 new homes required in South Warwickshire within the plan period, there is an identified potential supply of up to 19,950 new homes, of which only 6,145 new homes are identified as being capable of development within the Districts existing urban areas12 . Consequently, despite the Councils’ best efforts to maximise the utilisation of brownfield land, there will clearly remain a substantial need to allocate housing on greenfield sites across the plan area. The West Midlands Green Belt & the Cotswolds National Landscape AONB 4.12 Outside the main settlement areas in South Warwickshire, two significant planning designations limit the development potential of land in certain areas of the SW area: namely, the West Midlands Green Belt and the Cotswolds National Landscape AONB. 4.13 A significant proportion of the land that is considered, by the SWLP, to be within the most sustainable locations in South Warwickshire (i.e., the north-western extent) is covered by the West Midlands Green Belt, including land north-west of Stratford-on-Avon, Warwick, and Royal Leamington Spa. Paragraph 140 of the NPPF requires that: Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. 4.14 Given that the Councils’ have not yet undertaken the proposed Green Belt Study, to support a Green Belt review, the Issues and Options consultation is not capable of making an assessment as to whether such exceptional circumstances exist to justify the insetting of land from the Green Belt for the purposes of housing delivery. It is considered that, given the significant extent of land within the SW area that is not within the Green Belt, and as such able to accommodate housing development, exceptional circumstances do not exist to release land from the Green Belt. 4.15 On this basis, it would be difficult to conclude that any of the alternative spatial strategies would be appropriate as currently formulated. Following further technical work undertaken by the Councils’ to derive the availability, suitability, and achievability of potential development sites across the SW area, it would be possible to assess the spatial strategy options with a greater degree of accuracy. 4.16 To this end, Kingacre are able to confirm that the Land Adjacent to Grange Cottages, Hardwick Road, is available, suitable, and achievable for residential development within the next five years, in accordance with planning practice guidance. Supporting the Vitality and Viability of Rural Villages 4.17 In accordance with the discussion set out previously, Kingacre recommend that any spatial strategy for South Warwickshire includes the allocation of land to provide sustainable development at different levels across the current settlement hierarchy. 4.18 Such an approach would align with the general principle of Spatial Strategy Option 5, which would continue the delivery of the existing adopted spatial strategy in the Districts to support the sustainable growth of the larger settlements, whilst providing sufficient growth for the abundance of medium and smaller-sized villages in the SW area to support their sustainable growth. This strategy would also accord with paragraph 78 of the NPPF, which states: “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.” 4.20 Reductions in average household sizes, alongside low housebuilding rates, present a challenge for rural communities. Without an appropriate uplift in the level of development in these locations, there is a risk that local services in such areas would become unviable, undermining the vitality and sustainability of the rural villages across SW plan areas. 4.21 In addition to helping maintain the vitality of villages, medium and smaller-scale development in appropriate locations will assist with the housing delivery, both in the short-term and over the life of the SWLP plan period. Paragraph 68 of the NPPF states that local planning authorities should promote a good mix of sites, with small and medium sites often able to be built out relatively quickly. This is supported by updated research by Lichfields, which reports that schemes of 500 dwellings or more take on average between 5 to 8.4 years from the validation of an application for outline planning permission to the delivery of the first new home. The consequence being larger sites typically only substantively contribute to new housing delivery later on in the plan’s lifespan. 4.22 As such, Kingacre recommends that the Council should be seeking to allocate sufficient small and medium sized sites to maintain housing delivery throughout the plan period. Furthermore, Kingacre encourages the Council to seek to secure efficient delivery of new homes from any future proposed site allocations, i.e., maximising development potential whilst ensuring appropriate local character and context are respected. This would be particularly important for the smaller and medium-sized sites, which would help to ensure the SW area meets its housing needs from the shorter-term. Q-S8.1: Yes, small-scale development is essential within rural communities to ensure the continued vitality and viability of the numerous smaller villages within South Warwickshire. Q-S8.2: Small-scale development is essential within rural communities to ensure the continued vitality and viability of the numerous smaller villages within South Warwickshire. What constitutes appropriate development will depend upon the specific circumstances of each site, it is therefore considered inappropriate to apply an arbitrary number to the maximum number of homes considered to be appropriate on such sites. Furthermore, given a limit of 10 dwellings per site, it would be unlikely that much (if any) affordable housing would be provided on development sites in rural communities if this threshold was applied. Given the stark need for affordable housing, particularly within smaller villages, the implementation of this threshold is considered to be inappropriate and larger sites should be considered appropriate depending on the context of that site. It is recommended that small-scale development at smaller villages should be assessed on a case-by-case basis.

I understand from the Wilmcote Parish Council that up to 500 homes are potentially planned for this area. This raises real concerns, as over the last few years we have seen massive building projects in Stratford (most recently in Bishopton), and have seen the consequent impact on infrastructure (roads, lighting, etc.) and the environment. An additional 500 homes would double the size of our village. We created a Neighbourhood Plan which honoured the historic and green environment of the village, which is home to one of the Shakespeare houses. Residents voted democratically to work within the current Green Belt legislation to preserve the rural character of the village by keeping further housing developments (since those of Swanfold and The Glebe) to limited infill and brownfield sites. There is not the infrastructure to support the massive increase in car traffic, shopping needs and schooling to cope with such a doubling of the population. I would expect that for the massive scale of the housing needs of the area, you must be looking to create new communities, complete with schooling and shops, along the lines of Meon Vale?

In our view the Green Belt was set up to satisfy a number of very worthy purposes. Any diminution in size would frustrate these purposes for the existing population. In any case, such an increase in population as envisaged in these plans is to be discouraged.

Q-S4.1: 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-S8.1: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. I do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Q-S1: 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 Government’s 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’. QS1a Yes this should study be produced in advance of the Nature Recovery Network, as it is a very important bit of local work and needs to inform ‘Sound’ locations of growth. This is also a legal requirement in the NPPF. The 2013 Green Infrastructure study is also now 10 years out of date, and considered very outdated. This needs to be reviewed early on and in detail, in order to deliver joined up habitats and influence the spatial options. This should be produced based on Natural England’s new GI Framework Green Infrastructure Home (naturalengland.org.uk) The Nature Recovery Strategy will also take some time to produce, so we need a policy in the interim. Q-S4.1: 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-S8.1: A threshold approach to small scale development is not appropriate in greenbelt areas. The plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Q-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. Wellesbourne 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, Wellesbourne scores similarly to the other small settlements assessed. It is noted that other small settlements score higher than Wellesbourne against Education and Accessibility. This is discussed in more detail in following sections however Wellesbourne has a primary school and has the Wellesbourne Campus of the University of Warwick located north of the main village. It should also be noted that the SA at this stage does not consider any mitigation. Growth at Wellesbourne 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 Site ref: 463) 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 development boundary for Wellesbourne should be reviewed which would allow for the inclusion of this Site (Call for Sites ref: 463) within the development boundary to deliver sustainable residential growth.

9. Land at Walton Road, Wellesbourne 9.1. Rainier Developments is promoting land at Walton Road, Wellesbourne for residential development, inclusive of on-site green infrastructure. 9.2. The land comprises of an agricultural field, with associated agricultural buildings in the north-western corner and an existing access via Walton Road located close to the buildings. The site is located in between two new residential development, both built out by Persimmon. The site to the north-west (known as Ettington Park) is complete and occupied. The site to the south (known as The Grange) is continuing to be constructed and is partially occupied. 9.3. It is clear that these residential developments have changed the character of this part of Wellesbourne which is now typified by modern residential development. The development of this site would form part of this context and would effectively round off the settlement in this location. Walton Road forms a clear boundary for development in this area. The land beyond Walton Road is constrained by the River Dene and is unlikely to be suitable for large-scale development. 9.4. The accompanying Illustrative Masterplan (please see Appendix 3) shows how the site could accommodate circa 65 dwellings. This shows how the majority of the existing boundary vegetation could be retained and enhanced. The masterplan shows on-site open space located to link with the public open space on the adjacent housing developments. Access is proposed via Walton Road and a technical note has previously been prepared and submitted (please see Appendix 4) which confirms a suitable access arrangement can be achieved. Sustainability Appraisal SA 9.5. This site is located in the small settlement of Wellesbourne, as shown on Figure C.19.1. The site appears to fall between the area identified as the built-up boundary and the small settlement boundary (identified by a brown outline) on this figure. The site adjoins the built-up boundary and should clearly be considered as part of any housing growth in Wellesbourne. 9.6. The assessment of Wellesbourne against the SA objectives is presented at Section C19.1 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 site within the settlement. Each SA Objective is considered with specific reference to the site below: 9.7. SA Objective 1 Climate Change: The site would deliver circa 65 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support the delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs as it would benefit from access to existing service and facilities in Wellesbourne. 9.8. SA Objective 2 Flood Risk: The site is entirely within Flood Zone 1, land at lowest risk of flooding. There are areas of surface water flood risk, predominantly parallel with Walton Road however this could be addressed by suitable design and sustainable drainage systems. It should be noted that much of the undeveloped land, particularly in the north of Wellesbourne, is constrained by flood risk with significant areas of flood zones 2 and 3 present, associated with the River Dene and River Avon. 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. It is acknowledged that the site is within the Impact Risk Zone for Loxley Church Meadow SSSI however this could be addressed by suitable mitigation. 9.10. SA Objective 4 Landscape: The site is characterised by modern residential development on two sides. The Ettington Park development adjoins Walton Road, as does The Oaks, a small office development which immediately adjoins the site. The Grange locates the open space towards Walton Road however this development is to the south of this Site, beyond the Grange is agricultural fields. The Site would continue the existing build line along Walton Road as established by Ettington Park and The Oaks. The Illustrative Masterplan (enclosed at Appendix 3) shows how the site could be designed with on-site open space to link in the open space provided by the Grange. This would create a coherent development and minimise any landscape impacts through good design. A landscape note has previously been prepared for this site and submitted to the Council (see Appendix 5). This Note concluded that the site benefits from total enclosure on three sides with only the eastern aspect towards the River Dene where sensitively designed buildings which reflect the local character can create an attractive settlement edge. 9.11. SA Objective 5 Cultural Heritage: The site is not located in proximity to any designated heritage assets. The listed buildings and Conservation Area are concentrated around Bridge Street/Ettington Road, to the north-west of the site and separated by existing development. The scheduled monument and registered park and garden referred to by the SA are located north-east of Wellesbourne and are a significant distance from this Site. 9.12. SA Objective 6 Pollution: The site is not located in proximity of an Air Quality Management Area (AQMA). The SA refers to the A429 as a potential pollution source. The Site is separated from the A429 by existing modern residential development so it is reasonable to conclude that any mitigation required for noise and air quality would be minimal and achievable. 9.13. SA Objective 7 Natural Resources: It is acknowledged that the Site would result in a loss of agricultural land however this would be a minor loss due to the relatively small site size. The Site is within a Mineral Safeguarding Area (MSA) however the site is relatively small compared to the MSA and given the location of adjacent residential development mineral extraction is unlikely to be acceptable in terms of residential amenity. 9.14. SA Objective 8 Waste: A development of circa 65 houses 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 frequent bus services on Ettington Road which provides frequent services to Warwick, Leamington Spa and Stratford-upon-Avon and access to hospitals. Wellesbourne benefits from a recently developed doctors surgery located within a mile of this Site. There is also good access to leisure and recreation facilities within Wellesbourne with scope to provide on-site open space and connections to the public open space being provided by the Grange. 9.17. SA Objective 11 Accessibility and 12 Education: The site benefits from existing bus stops on Ettington Road and frequent local services to Leamington Spa, Warwick and Stratford-upon-Avon. These locations have train stations for onwards journeys, including to Birmingham. There are also various local services and facilities within the local area, including a primary school. The secondary schools in Stratford-upon-Avon would also be accessible using public transport. 9.18. SA Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with Wellesbourne which include the Distribution Park and the Wellesbourne Campus of the University of Warwick. Summary 9.19. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.20. The Vision Document indicates how a scheme of circa 65 dwellings can be achieved having regard to the site constraints and opportunities. 9.21. The site benefits from a highly sustainable location within Wellesbourne 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. 9.22. The Illustrative Masterplan shows how the site would follow the existing building line along Walton Road as established by the developments to the north-west and provide on-site open space which would link to the public open space on the site to the south (known as the Grange) to provide a coherent development which rounds off this part of Wellesbourne. 9.23. 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. 9.24. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.25. 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. 9.26. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.27. 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. 9.28. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.29. 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. Shipston-on-Stour is identified as a town and as such is a sustainable location for development. This 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 Broad Location ‘Shipston-on-Stour North’ which the SA shows is the second best performing Broad Location in terms of environmental receptors (see Table at 4.10.1). Shipston-on-Stour North performed best in terms of accessibility, education and economy. 3.19. It is clear that this Site (Call for Sites ref: 460) 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, development boundary for Shipston-on-Stour should be reviewed which would allow for the inclusion of this Site (Call for Sites ref: 460) within the development boundary to deliver sustainable residential growth.

9. Land South of Darlingscote Road, Shipston-on-Stour 9.1. Rainier Developments is promoting land south of Darlingscote Road for residential development, inclusive of on-site play and green infrastructure. 9.2. The land comprises a single agricultural field which is defined by boundary vegetation. The existing farm building in the north-west corner of the site are excluded from the site boundary. The site is adjacent to the built edge of Shipston-on-Stour which comprises a mix of commercial uses to the north and is a majority residential settlement. In total the site comprises of 3.81ha (please see Site Location Plan enclosed at Appendix 2). 9.3. The site has previously been promoted through the emerging South Warwickshire Local Plan and the Stratford Site Allocations Plan (SAP). 9.4. The accompanying Concept Masterplan (see Appendix 3) demonstrate how the site could accommodate circa 90 dwellings and shows how walking routes could provide connections to the adjacent leisure uses. It also shows an area of play located adjacent to the boundary with the leisure centre to co-locate and consolidate the recreational use in this area. This has been informed by a Constraints & Opportunities Plan (included for reference at Appendix 4). Sustainability Appraisal SA 9.5. This site is located in area identified as Broad Location Shipston-on-Stour North. The site adjoins the existing built-up area boundary adjacent to the existing leisure centre. The site is shown as unconstrainted and would form a logical extension to Shipston-on-Stour. 9.6. The assessment of Broad Location Shipston-on-Stour North against the SA objectives is presented at Section B.18 of Appendix B. It is acknowledged that, at this stage, the assessment covers a wide area and the ratings will not be applicable to each part of the Broad Areas. Each SA Objective is considered with specific reference to the site below: 9.7. SA Objective 1 Climate Change: The site would deliver circa 90 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support the delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs as it would benefit from access to existing service and facilities in Shipston-on-Stour. 9.8. SA Objective 2 Flood Risk: The site is entirely within Flood Zone 1, land at lowest risk of flooding. There is a small amount of surface water flood risk along the site’s north-western boundary which runs parallel with the existing farm access road. This area is shown on the accompanying indicative masterplan as undeveloped green space, demonstrating that this small area of surface water flood risk can be avoided as part of any residential development. 9.9. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: The site is not designated as 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 site is located in the vicinity of the Shipston High School Sheep Field Local Wildlife Site however this could be mitigated by suitable design and landscape scheme. The SA notes that the SSSI Impact Risk Zone for Midsummer Meadow SSSI is triggered by proposals of 100 or more dwellings. The indicative masterplan for this site shows a maximum of 90 dwellings and therefore does not meet this threshold. 9.10. SA Objective 4 Landscape: The main concern under this objective for the Broad Location is landscape sensitivity and notes that the area includes high and medium sensitivity landscapes. It is acknowledged that this has necessarily been considered at a large scale at this stage and that landscape sensitivity will vary within the Broad Locations. Previous landscape evidence has been provided specifically for this Site (enclosed at Appendix 4) which sets out that despite the site’s location on the middle plateau, higher than the town, it has a limited range of intervisibility with publicly accessible routes in the wider area and the screening provided by the topography. Notably, the Site does not interrupt long distance views across the landscape. The recommended landscape strategy includes retention of existing boundary vegetation and careful consideration of building heights and materials. The concept masterplan shows how this could be achieved on this site. 9.11. SA Objective 5 Cultural Heritage: The closest designated heritage assets to the site are the Grade II Listed Buildings Shipston House and Our Lady & St Michael Church, both located between Darlingscote Road and Tilemans Lane. These are separated from the site by existing development and there would be no intervisibility between the site and the assets. 9.12. SA Objective 6 Pollution: The site is not located within or close to an Air Quality Management Area. The SA notes the proximity of the A4300 and the River Stour as potential minor negative impacts however these are located the other side of the Broad Location to this Site and are separated by the existing settlement. 9.13. SA Objective 7 Natural Resources: The site is shown on Natural England mapping as Grade 3 agricultural land. The Site would only result in a minor loss of agricultural land. The Site is within a Mineral Safeguarding Area (MSA) however development of the Site would be a minor in the context of the large MSA designation and would require consultation with the Country Council. 9.14. SA Objective 8 Waste: A development of up to 90 houses 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 an excellent location to the north of the settlement, close to the existing GP surgery and adjacent to the leisure centre. The site is also located close to the wellbeing zone identified in the Neighbourhood Plan to facilitate resident wellbeing and access to outdoor greenspace. 9.17. SA Objective 11 Accessibility and 12 Education: The site is adjacent to the High School and within a 6-minute walk of the Primary School. The site is well-located to sustainably access a variety of services and facilities which are primarily located in the north of the settlement. The closest bus stops are located on Darlingscote Road which are served by the 50, 51 and 75 routes which provide a good service to Stratford where onwards services can be accessed, including trains to Birmingham. 9.18. Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with existing employment uses in the north of the settlement. Summary 9.19. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.20. The accompanying Concept Masterplan indicates how a scheme of up to 90 dwellings can be achieved having regard to the site constraints and opportunities. 9.21. The site benefits from a highly sustainable location on the edge of Shipston-on-Stour and is well placed to meet the housing needs of Shipston-on-Stour and the surrounding area. The site is well-placed to ensure easy access to a range of services and facilities, particularly employment, education and recreation. 9.22. More detailed landscape evidence has been provided to demonstrate that the site is capable of being development without undermining the character of the landscape. 9.23. 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. 9.24. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.25. 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. 9.26. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.27. 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. 9.28. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.29. 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.

Introduction 1.1. These representations are made by Pegasus Group, on behalf of Corbally Group (Harbury) Ltd., (hereafter Corbally Group), in response to the Issue and Options consultation for the South Warwickshire Local Plan. 1.2. These representations relate to land covering some 10ha at Harbury Depot (hereafter ‘the Site’), lying to the north of Bishops Itchington and adjoining the recently developed Barratt David Wilson (BDW) residential developments known as ‘Bishops Hill and the ‘Willows’’. The Site is identified on the Location Plan at Appendix 1 and is being promoted as being available, achievable and deliverable, with the capacity to deliver some 210 homes. The Site was promoted through the 2021 Scoping and Call for Sites consultation and is identified on the Council’s interactive maps [redacted text] with Site ref: 144, noted as being a Housing/Residential proposal. The detail of the Call for Sites submission is not repeated within these representations, but specific comments are made where appropriate to respond to the questions identified in the Issues and Options consultation. A copy of the Vision Document submitted alongside the Call for Sites is further attached here as Appendix 2. These representations have had regard to the published consultation document and questions set out therein, accompanying documentation forming the current evidence base, and the national planning context. 1.6. The tests of soundness that Development Plans need to meet so as to be legally compliant and found sound, are set out in the National Planning Policy Framework 2021 (NPPF), paragraph 35: • Positively prepared – providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; • Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; Effective – deliverable over the Plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and • Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework. 1.7. These tests of soundness, along with other legal and procedural requirements associated with the plan-making process provide a contextual framework for these representations. It is noted that the consultation changes to the NPPF published in December 2022 propose to remove the requirement for Development Plans to be ‘Justified’ in order to be found sound. However, at the time of writing and submission of these representations that change has not been enacted, is the subject of significant representations not least from the RTPI who note in their response on the NPPF consultation that; ‘Any suggestion that plans need not meet this high bar must be resisted.’ These representations therefore still take the test of ‘justification’ into account. 1.8. These representations refer directly to the specific questions set out in the Issue and Options consultation document and also respond to the following evidence base documents where appropriate: • South Warwickshire Local Plan Part 1 Stage 2: Issues and Options Consultation, January 2023 • Sustainability Appraisal (SA) November 2022 • Housing and Economic Development Needs Assessment (HEDNA) November 2022 • Urban Capacity Study, October 2022 • South Warwickshire Settlement Analysis, January 2023 • Evolving the Spatial Growth Options – The Story so Far – Topic Paper, August 2022 Land at Harbury Depot, Harbury 9.1. Corbally Group has an interest in land at the Harbury Depot site, Bishops Itchington. It has been identified as Reserve Site by SoADC in their October 2020 Site Allocations Plan (SAP) Reg 18 Consultation and the July 2022 SAP consultation. The site is now identified as Site 144 in the South Warwickshire Local Plan Scoping and Call for Sites interactive mapping tool. 9.2. The site relates well to the recent BDW development of ‘Bishops Hill/Willows’ located to the south, and development would provide the opportunity through critical mass, to provide some small-scale community facilities to support both developments. There are no statutory designations nor constraints covering the site that would preclude its development. 9.3. Corbally control land at Harbury Depot and have successfully promoted the core of the old cement works site for residential development, outline planning permission for up to 200 homes was granted in September 2014, with an outline approval for a further 80 dwellings granted in September 2016. 9.4. Both of these outline approvals progressed rapidly to Reserved Matters approvals, and the site is now nearing completion. This provides evidence of both market demand in this location and Corbally’s local track record on rapid delivery. This site could be delivered within 5 years. 9.5. The site is identified as a Reserve Site through the SoADC SAP under reference LRS.B (previously LSL.04B) as having the potential to deliver some 210 dwellings. 9.6. Detailed work has been undertaken to establish baseline matters such as soils, drainage, ecology etc, and there are no constraints to the early release and development of the site, which is capable of delivering new market and affordable homes within the next 5 years. 9.7. To support the delivery of the site, and its promotion through the South Warwickshire Local Plan process, a detailed Vision Document has been produced to demonstrate the site's capacity, and technical deliverability (Appendix 2). The Vision Document is submitted alongside these representations and should be read in conjunction with them, it confirms inter alia, that from a landscape and visual analysis, the site is well placed to accommodate development without any significant impacts into what is an ‘unremarkable local landscape character’. The Vision draws on evidential work which has been undertaken in respect of the Phase 1 and 2 elements of the consented scheme (built out by BDW), with regard to understanding matters such as drainage, ecology, transport and noise, and has been updated with additional evidence to support specific landscape and design considerations. The Vision supports the emerging SoADC SAP identification of the site as a sustainable location for new development, capable of accommodating circa 210 dwellings. The site is within 0.6 miles of the nearest shops and services in Bishops Itchington including a post office, convenience store, Co-Op food retail and doctor's surgery, all of which are accessible by footpath through the nature reserve to the south that leads directly into Bishops Itchington village centre. 9.9. The Vision Document recognises the potential to also introduce a small local centre element to the scheme, which alongside the existing consented Phases 1 and 2, will be an element of viable supporting local infra-structure, to complement existing facilities in Bishops Itchington, but which Phases 1 and 2 alone were not able to economically support. 9.10. The new infrastructure and access introduced off Station Road to serve Phases 1 and 2 has both improved the immediate road network and has sufficient capacity to accommodate the development of this Site. The use of that infrastructure to access this Site is not constrained by third party landholdings or the requirement for upgraded site access infrastructure. 9.11. The Vision Document analyses the site context, its setting within the landscape, its proximity to existing facilities, public transport, and the major employment area of Gaydon/Lighthorne Heat - JLR (less than 4 miles distant) and through a process of establishing both constraints and opportunities, draws together an illustrative masterplan for how the site could be delivered. The Council are invited to review the Vision Document, and recognise the benefit that early delivery of the site could bring, both in terms of; 1) meeting any housing requirement within the next 5 years, in a manner consistent with an overarching spatial strategy which continues to acknowledge the role that development around some of the smaller settlements will bring, and, 2) enhancing the sustainability of the existing Phase 1 and 2 BDW developments. Conclusion 10.1. This representation has been prepared by Pegasus Group on behalf of Corbally Group (Harbury) Ltd. 10.2. Corbally are promoting land at Harbury Depot for residential development. The land is sustainably located adjacent to the newly developed Bishops Hill and Willows developments, and is well related and connected through that to Bishops Itchington, and its social and physical infrastructure. This land is suitable, available and deliverable and should be identified as a location for future residential development as part of the South Warwickshire Local Plan. 10.3. This representation demonstrates that there are no significant constraints that would preclude the development of the site for residential development. The Vision Document shows how circa 210 homes can be accommodated on the site, along with on-site open space, landscaping, BNG and sustainable drainage. 10.4. Corbally Group welcome the opportunity to comment at this early stage of the plan preparation. If the Council require any further information in respect of the site in order to fully assist in the assessment of this site, this can be provided upon request.

Q-S3.2: It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.14. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S8.2 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. 3.27. 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. 3.28. 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, perhaps in a range to reflect the existing settlement scale, would allow for an appropriate higher level of development and support greater on-site affordable housing provision. Q-S9: 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. 3.30. It is considered that a combination of both options may be appropriate for the Joint Local Plan. Where the Plan seeks to allocate land for development for strategic sites as set out at paragraph 1.4 of the Issues and Options document, then reviewing settlement boundaries should be undertaken as part of the proposed site allocation. 3.31. 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 locations to meet the development needs of the Plan. It is considered that a review of settlement boundaries would be an appropriate approach for the Joint Local Plan.

Relating to WILMCOTE village Expansion proposals: !. Wilmcote is within the Green belt. Further development will create a precedent for similar encroachments. 2 The village school is small and in a completely enclosed site, It has parking problems and no playing field.. Additional population would require a newly sited school. 3 Wilmcote is a tourist village with Shakespeare Birthplace Trust properties, significant expansion would alter its character as perceived by its many visitors 4 The village been selected as having a Railway Station where there are no parking facilities. The entrance to any new station parking would be situated dangerously 5 The Billesley Road site offered for possible development, is at least half a mile from the Station, on a road partly without pavements. Train passengers would simply drive to the station defeating the object. I trust you will take these comments into account when finalising the Plan.

As a frequent visitor to Wootton Wawen I am lodging my objection to the proposed housing development. Wootton Wawen is a lovely English village with a close-knit community at it’s heart. This proposal will destroy it’s character. Roads will have to be widened to accommodate increased traffic,wildlife will disappear, hedgerows and footpaths will be destroyed. We know how much open spaces/countryside improves our physical and mental wellbeing, which is needed now more than ever. We should respect and protect our countryside for future generations. SAY NO TO THIS PROPOSED DEVELOPMENT

Q-S1: S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. If the Local Nature Recovery Strategy is likely to come AFTER the SWLP Spatial Growth Strategy has been determined it makes sense to at least have some policy of guidance in place.

I am a resident of Henley in arden and strongly object to the proposal for 500-2000 new homes. I moved here nearly 14 years ago, in order to raise my children in a small community, and love the fact that everyone knows everyone, it is safe for my children, people will let me know if my teenagers were doing something they shouldn’t be as they are well recognised in the village. I love the fact that I live in an aged, heritage area, where I can hear sheep and cows when I stand in my back garden. I count myself blessed to live here. Prior to moving here, I lived on the sprawling urban area of monkspath on the edge of solihull for 11years. It was soul-less, and I knew nobody. No sense of community, no heart, just additional housing that I appreciate is necessary. Henley however, is not the site for that kind of growth. It will change the whole feel of the place. It has not got the infrastructure to manage such development. When the m42/m40 is closed, the roads cannot cope anyway; a few weeks ago, when the village’s main traffic lights were out, you could barely get through the village without adding an additional 45mins to your journey, how would the highstreet cope with the traffic such proposals will bring? What damage would be caused to our beautiful, ancient, heritage buildings? I am not against growth, and know it is needed, however, anymore than a 10% expansion would kill the sense of community; overwhelm our infrastructure; remove the lovely country feel that the village has and bring nothing but difficulties for our small, but close-knit community.

I have been looking at the above plan and note that there is a proposal for a large area of housing around the area of Terrys Green I object to this based on the local infrastructure would not be able to support this i.e. access via the causeway and Malt House Lane is unsuitable. The sites highlighted on the plan are too close to Clowes Wood which is a site of special scientific interest. There are not enough facilities in the area to support this development e.g. Schools and shops etc. Surely it is a better option to look at developing Brown Fields sites first Please add my name to the list of objections

I would like to register my objection to the proposal for building and development on the North Leamington Green Belt which is covered in Chapter 4, Issue S6 of the consultation. Building and development on this area of green belt would: • Remove vital green space, which is currently helping to at least manage the poor air quality we have to live with on a daily basis across both Leamington and Warwickshire due to high levels of traffic • Put additional pressure on inadequate local infrastructure which despite promises/reassurance never actually gets upgraded to the required standard when developments occur - for an example of this in action see the significant road/congestion/air quality challenges the development to the south of Leamington is causing already and it is not even complete yet • Remove a crucial area of open space access which provides considerable mental and physical health benefit to citizens I also note that similar proposals were rejected 6 years ago for the reasons stated above alongside some other. These reasons have not changed, and in some cases have strengthened, since this rejection so there is no rational basis for this decision to be overturned. In addition this proposal (i.e. consideration of Greenbelt for development, which is deemed a genuine constraint) is not inline with current government policy.

Re: Proposed Housing Development in Wootton Wawen I stay in Wootton Wawen frequently as i love the area with its beautiful countryside, trees and walks. The wildlife I have seen is amazing and also the abundance of wild birds. The village is a welcoming place with a close knit community, very friendly and caring. I live in the village of Knowle which was once a beautiful small village but has now unfortunately become a much bigger place with far too many houses and totally spoilt the ambiance of the village. It is not the friendly, caring place it once was and very few people are recognised as there are now so many. Too many people, too many children at the schools who vandalise our property and have no respect. The roads are chocker block with cars and congestion. The shops are not able to provide sufficiently for the amount of people now living here. I would not like Wootton Wawen to become like Knowle and hope the proposed housing development will not be allowed to go ahead. The proposal will destroy the character of the village. More roads will be needed, more fields and hedgerows torn down to accommodate the increased number of people and wildlife habitats eradicated. This is an outstanding area of natural beauty and should be left as it is for everyone to enjoy. SAY NO TO THE PROPOSED HOUSING DEVELOPMENT.

May I add my name to those who support the maintenance of the Green Belt without any change of boundaries.

As a resident of of Warwick District (Leamington Spa), I am once again disappointed that the Green Belt around North Leamington is under threat. I think the council are greedy for allowing the land to be built on by private developers. It should be protected green belt for the following arguments: 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. We 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. I urge you for the above reasons to maintain invaluable green belt areas in the locale. I don’t understand why the Council make such awful decisions against the wishes of local people and instead of improving the town and making it a nice place to live, the Council chase private money in endeavours that the local public don’t want as it spoils the town, makes it more polluted and unsightly. Have you not heard there is a climate crisis? So why are you even thinking about trashing the green belt? Why don’t you care?

As a resident of of Warwick District (Leamington Spa), I am once again disappointed that the Green Belt around North Leamington is under threat. I think the council are greedy for allowing the land to be built on by private developers. It should be protected green belt for the following arguments: 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. We 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. I urge you for the above reasons to maintain invaluable green belt areas in the locale. I don’t understand why the Council make such awful decisions against the wishes of local people and instead of improving the town and making it a nice place to live, the Council chase private money in endeavours that the local public don’t want as it spoils the town, makes it more polluted and unsightly. Have you not heard there is a climate crisis? So why are you even thinking about trashing the green belt? Why don’t you care?

I am writing with respect to the suggested housing / building plans for the small village of Wilmcote near Stratford-upon-Avon. Prior to building any additional housing in this area, please can you provide clear evidence that the following issues have been considered, in detail, with full consultation from local residents. A. Green Belt land. Any buildings would significantly change the character and appearance of this beautiful location. B. Conserving and enhancing the historical environment. Wilmcote contains areas of national (and international) historical and cultural importance being the location of Mary Arden's Farm. Building on protected green belt near such important historical sites would require a full heritage assessment and any buildings built here would need to be sympathetic in style to the current buildings. C. Highway safety. The central part of Wilmcote is a small, quite narrow road, with a school very close to the road, thus any increase in traffic or parking would cause major highway safety concerns. D. Other issues, including school capacity, international tourism and biodiversity, all need addressing. To expand on these considerations further, I have provided some of details that require addressing: A. Green Belt Land According to government guidelines on Green Belt regulations (see https://www.gov.uk/guidance/green-belt) there are 3 main considerations that need to be taken into account before any building decision has been made. 1. openness is capable of having both spatial and visual aspects – in other words, the visual impact of the proposal may be relevant, as could its volume - The proposed sites are primarily on the entrance routes into the village, which would not only increase traffic and pollution, but reduce the overall greenness of the area, which is one of the main features of this much-loved village. - The proposal needs to take into consideration how UK and international tourists perceive this area; it is known as a protected place that reflects the traditional and historical beauty of England. 2. the duration of the development, and its remediability – taking into account any provisions to return land to its original state or to an equivalent (or improved) state of openness - if you build on it, you will block the openness of the area and that cannot be returned once it is damaged by building work. - building on this green belt land would be highly disruptive to local residents. 3. the degree of activity likely to be generated, such as traffic generation. - Increasing traffic into the village would be detrimental to the local people and for tourists visiting Stratford. The location is known for the beautiful green surroundings and reducing such areas of beauty will seriously impact perceptions of this historical area of national importance. -There are very few roads in and out and by proposing to build on two of them would mean that the traffic generated from the building work (and the new residents) would have a significant impact on accessibility - Increasing traffic would also be detrimental to the educational benefit of Mary Arden's farm - since this historical site is currently being primarily used by schools from around the UK, accessibility is essential. - The area simply does not have road capacity for additional traffic. The central road through the village is very narrow, with a school right next to the road. Parking is already a major issue and it would be dangerous to have large building vehicles going through the village (which would happen) or anywhere near the school. B. Conserving and enhancing the historical environment. With respect to changes to any historical environment, the government has guidelines (https://www.gov.uk/guidance/conserving-and-enhancing-the-historic-environment). This states that: "Any decisions where listed buildings and their settings and conservation areas are a factor must address the statutory considerations of the Planning (Listed Buildings and Conservation Areas) Act 1990 (see in particular sections 16, 66 and 72) as well as applying the relevant policies in the development plan and the National Planning Policy Framework." Given that Wilmcote is home to a very famous listed building, the setting and surroundings need to be given serious consideration before any building work is undertaken. - Has a FULL heritage assessment been made of the site? As the guidelines state, "part of the public value of heritage assets is the contribution that they can make to understanding and interpreting our past". Therefore, before engaging in building work, please provide documents outlining the justifications provided for the partial loss of this heritage asset. - It is noticable that the map provided on the website (https://soadc.maps.arcgis.com/apps/webappviewer/index.html?id=c9f9579706974081a054de1b14a66130) does not contain details of any designated and non-designated heritage assets within the plan area. The government guidelines state that it is beneficial to clearly identify these "at the start of the plan-making process so they can be appropriately taken into account." Therefore, please provide these details. - please outline how exactly the proposed building work has been kept in line with the National Planning Policy Framework (paragraph 185). All plans should set out a positive strategy for the conservation and enjoyment of the historic environment; however, building on the only routes in and out of Wilmcote seems counter-intuitive to the conservation or enjoyment of this historical location. Since this location is most known for the green surroundings, it is hard to see how the delivery of development will make any positive contribution to, or better reveal the significance of, the heritage asset. - If building work is undertaken, then it is also important to consider the type of building work undertaken. As government guidelines (https://www.gov.uk/guidance/conserving-and-enhancing-the-historic-environment) state, the proposed building plans need to "reflect or enhance the local character and distinctiveness with particular regard given to the prevailing styles of design and use of materials in a local area." The style of housing in Wilmcote village is integral to its charm, so it is important that the main routes into the village reflect this heritage. Therefore, please provide documented evidence on the style of housing proposed on Green Belt land (near an area of historical importance), prior to commencing with the building work. C. Highway safety. In addition to these problems, the village simply does not have the infrastructure to support development. - There are only a few roads in and out of the village. The central road is very narrow and cannot support a higher volume of traffic - it is already quite dangerous due to narrow paths right next to the school and parking is a major issue. To increase housing would mean an increase in traffic which would increase the risk to school children. - There are limited bus services and a very small train station to Wilmcote - most people visit on the open-top bus or drive. Thus any expansion on housing will have a serious impact on the village, unnecessarily increasing the number of cars and traffic. D. Other considerations School Capacity The village school is loved by residents due to the historical nature of the buildings, however it can only support a small number of pupils (which is part of its beauty), so does not have capacity for the high volume of extra children needing school provisions if additional housing projects go ahead. International Tourism Wilmcote has a lovely small village shop and 1 pub. Thus it has the feel of a small, beautiful English village whilst being close enough to Stratford town centre to allow for visitors. This is part of its charm. Biodiversity The biodiversity and closeness of protected woodland also add to the importance of protecting the greenery surrounding the village.

I would like to register my objection to development of Green Belt land to the north of Leamington. 1. The Green Belt north of Leamington is important for many reasons: • It is high quality agricultural land which should be safeguarded for the sake of national food security. • • Its footpaths offer recreational and health benefits for many people in the town of Leamington Spa who can access the area on foot. The number of people using the footpaths increased hugely during periods of lockdown and this has continued since. • • It prevents a sprawling northwards of the town of Leamington Spa and forms a green ‘northern gateway’ to the town. This in turn helps Leamington to maintain its setting and special character. • • It helps to maintain the distinct identities of the towns of Kenilworth and Leamington Spa and prevents them merging into one another. • • It assists in urban regeneration, by encouraging the recycling of derelict and other urban land, in line with the Government’s “Brownfield First” pledge. 2. It is not necessary or appropriate to develop the Green Belt north of Leamington because: • It is not in line with current Government policy. • • The statistic used in the consultation in support of Green Belt development is misleading. This says that 54% of respondents support the exploration of Green Belt growth opportunities, without mentioning that 45% of respondents were developers, landowners and businesses. • • The Green Belt north of Leamington fulfils all five of the stated purposes of the Green Belt. • • The Green Belt north of Leamington is high quality agricultural land which should be safeguarded to promote food security. • • The planning team explored options which placed development outside of the Green Belt yet it has presented none of these in the consultation document.

I hope the comments made from the event held in Ashow on Saturday 4th March have been forwarded on and form part of the local plan decision. From the documents it appears that there are two areas proposed for development in and near Ashow. The area off Grove Lane is suggested suitable for 10+ residential properties. This would be a disproportionate increase in the population size of a small village. Access is limited, Grove Lane is only wide enough for a single vehicle to pass, and with no bus links, access to mains sewer waste, or the gas network, the infrastructure is not in place to support this. The proposed development is on current farmland, further impacting and reducing the green zone. Ashow is already very close to an extensive development at thickthorn, which although falling outside the parish, will provide numerous houses, shops, school and industrial premises in the close vicinity. The local impact from development of HS2, and associated erosion of green space should also be considered. Any residential development in Ashow should be proportionate to the size of the village, and in keeping with predicted population growth and need, not expansion beyond this. Regarding the proposal for light industrial premises opposite dial house farm, again this is using green belt land where there are numerous brown field sites underutilised in the region. The junction of the A452 and B4115 is extremely tight, and would likely need significant work to make suitable. The in fill of green land, eroding the boundary between village (Ashow) and town (Kenilworth) would continue, losing the village identity of Ashow. Whilst the need for development is understood a more specific plan needs to be brought forward, and planning / development should be fair for all as the system currently seems to allow new development in green belt areas but is highly restrictive to changes of properties already present.

Q-S1: Option S1a: There should be sufficient existing technical evidence already available to identify the corridors. There would also be scope for these to be modified, as necessary as the local plan progresses. If this approach is taken it is important that maps and images are at a scale and have sufficient clarity so that the status of specific land parcels can be distinguished. Option S1b: It seems unlikely that the scope for any reduced synergy would be very significant and, as mentioned above, there is scope to reduce that as the local plan progresses towards adoption. Q-S2: Option S2b would appear to be the most realistic, and achievable option. It is of some concern that the consultation document identifies some of the potential climate change benefits that can arise from intensification while at the same time failing to recognize potential dis-benefits such as adding to congestion in already congested areas and undermining the character and appearance, as well as the attractive of urban areas though over-intensification. In addition, since all development should be carbon-free by 2050 the differential impacts on climate change between different locations should be significantly reduced. The plan appears to be predicated on a principle that development in urban areas is preferable in climate change terms that development elsewhere. This appears to be a principle based on assertion rather than definitive evidence. It could lead to the degradation of attractive urban environments which would be counter-productive. Q-S3.2: These options and the analysis behind them appear somewhat confused and focused towards urban concentration. As highlighted earlier in this response, the evidence to conclusively prove those options are the most sustainable and have the least impact on climate change and CO2 reduction is based more on assertion rather than on conclusive evidence. We also feel that the term 'prioritise’ may not be the most suitable, not least because of its uncertain meaning. Perhaps ‘make best use of’ would be a better terminology. Q-S8.2: A 10 dwelling limit generally seems appropriate although any such limit should also be caveated to enable developments of more than 10 dwellings in exceptional circumstances or where criteria have been met in terms of sustainability and perhaps provision of additional infrastructure, otherwise potential developments of 11-49 dwellings which might be acceptable on all other grounds would have been excluded from the local plan process. Q-S9: The development strategy should enable a proportion of development to come forward outside strategic sites with a capacity of 50 or more dwellings. The scale of small scale dispersed growth should be disaggregated across the plan area to provide the basis for Neighbourhood Development Plans and the review of settlement boundaries where this is necessary. However, it is important that identification of suitable sites is not unduly delayed and the potential identification and release of an appropriate scale of development where sites have been taken through the Call for Sites should not be unduly delayed. Ideally, where it is known that settlement boundaries require amendment then these settlements should, at the very least, be identified in the plan. If, having identified these settlements then it should be accepted that land might be released adjacent to the extant development boundary. This would provide a strong incentive for Neighbourhood Development Plans and or Site Allocation Plans to be put into place. Q-S10: The level and distribution of growth should be clearly set out in the plan to provide a sound basis for Neighbourhood Development Plans.

I'm writing to object to plans that threaten precious green belt land in North Leamington. Green belt laws were created to stop urban sprawl and if these plans are realised there will be very little divide or boundary between Leamington and Kenilworth. I also feel that as a town we are losing green space at a rapid rate especially due to the Hs2 and housing developments around Whitnash and Warwick Gates. The green belt land should be protected and preserved for future generations. As someone with a family who enjoys walking in the proposed area (174) it would mean that we would have to drive to the next nearest green space adding to road traffic. This area was a haven during lockdown and is used consistently by local families, dog walkers and retired people for leisure and recreational use. Currently schools in our local area are full so would add further demand and pressure to local schools. Losing agricultural land would negatively affect food security too. As a country currently suffering vegetable shortages surely we should be protecting this asset.

The Henley & Beaudesert Society was originally formed in 1967 to preserve and safeguard the character of the town and the surrounding area. The Society wishes to strongly object to the SWLP that wishes to double the size of the town by building some 2,000 properties. Although the Society is aware that the need to build more homes in Warwickshire will mean some development in Henley, the scale of this plan is totally unsuitable and would destroy the character and setting of this historic town in the wider landscape. Over the last 56 years since the Society was formed there have been several large scale plans to develop around Henley. All these plans have been met with large-scale objection from the residents of Henley because of the detrimental effect it would have on the infrastructure of the town. The SWLP ignores the local feeling about such large-scale development in and around Henley and the importance of the Green Belt. The Village Design Statement; Local Plans and Conservation Area Policy all make reference to the opposition to large scale development around Henley; the importance of the local topographical boundaries and the importance of the Green Belt that surrounds the town.

Ruination of the habitat and trees Outcry once trees have been cut down so DON'T CUT THEM Down IN THE FIRST PLACE! More congestion on the roads and fumes we will become a concrete jungle No green land left to enjoy. LEAVE OUR GREEN LANDS ALONE, THEY ARE VERY PRECIOUS

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