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

3.20 The Consultation Document sets out that both the Stratford-on-Avon Core Strategy and the Warwick Local Plan set out settlement boundaries for some or all of the settlements in their area, and that they establish where new non-strategic small-scale development may be appropriate within the confines of existing settlements. Two options are proposed, offering two different approaches to setting settlement boundaries in the SWLP. 3.21 It is unfortunate that there is not an option for removing settlement boundaries altogether and using a more nuanced and sensitive approach to assessing the appropriate-ness of development within and adjoining settlements in South Warwickshire. Settlement boundaries are inevitably drawn tight to the built form of settlements and are set out as an absolute limit to development, with any proposals beyond the boundary assessed as being in open countryside, even if the site is contiguous with the settlement, close to existing facilities and represents clear rounding off. In these circumstances, perfectly sustainable proposals for development may be assessed as inappropriate simply by virtue of being on the wrong side of an arbitrary line. In the most unfortunate examples, a settlement’s opportunity for modest growth which would sustain services and enable local people to find homes in their community can be thwarted by a settlement boundary. 3.22 We would suggest that settlement boundaries are not carried forward into the SWLP. Other policy approaches are used in other parts of England which enable judgements to be made on a case-by-case basis, with reference to the status of a settlement in the settlement hierarchy – which we note is already in existence for Stratford-on-Avon as set out in the Core Strategy Policy CS.15. An example of an approach which would be very successful in South Warwickshire can in fact be found in the Local Plan of the neighbouring West Oxfordshire District Council, which applies an infill and rounding off policy to its settlement hierarchy without reliance on settlement boundaries. This approach has allowed for a nuanced approach to village development in very sensitive landscape settings, which has led to highly successful developments in appropriate locations for many years and has been continued in successive local plans.

The SWLP should examine ALL other options first. Green Belt status should be preserved if it meets ANY ONE of the defined 5 purposes as defined in NPPF. Environmental and ecological concerns should take priority, to help combat climate change. Green belt should also be preserved for aesthetic and recreational reasons. Future generations should not be deprived of it. HS2 is doing far too much damage in this area already. Housing is necessary, but constructive alternative solutions should be sought first.

1. Where I live in Milverton is close to fields, fresh air and open space which is why I chose to live here. 2. Leamington is a town not a city and excessive developing on green belt countryside detrimental for environmental (wildlife habitat i.e. bats, birds, and small animals) and mental health reasons. 3. Building close to Milverton and Blackdown is a long way from public transport i.e. trains, and buses. 4. Humans need more quality farmland to eat more fruit and vegetables if we are not to have serious diseases and illnesses (there are way too many obese people in the world who could do with eating more vegetables). 5.

1. The SWLP Process should fully examine other options including the use of brownfield sites within existing settlement boundaries before contemplating the revision of the existing Green Belt. With the change in work patterns due to the pandemic and the resultant working from home there are large numbers of office buildings which are unused or underused. The Planning System should encourage the use of these sites either for new build or conversion instead of looking to expand the outer edges of a settlement which would endanger the Green Belt. 2. The National Planning Policy Framework is very clear that an area should maintain its Green Belt status if it meets any one of the 5 purposes of Green Belt. 3. The removal of the Green Belt to the North of Leamington Spa could lead to the town engulfing villages such as Old Milverton which currently lie within Green Belt.

There is no consultation for Issue 6 - why is this? This discusses Green Belt Boundary reviews as if already agreed as a legitimate area for development which is not the case and not aligned with the Government's guidelines on Green Belt. South Warwickshire has borne considerable destruction of bio diversity, green space and ancient woodland due to existing HS2 project. Further green belt removal will negatively impact the area, its carbon footprint and bio diversity. Current projects like the Leamington - Kenilworth cycle route will be negatively impacted by development north of Leamington and cross town links are not able to sustain increased traffic volumes without negative impact on existing welfare and safety of the town's population.

I wish to object to the use of Green Belt land around North Leamington for future development for the reasons given below. New settlement options outside of the Green belt should be considered first. In accordance with the National Policy Framework an area of Green Belt land should maintain its Green Belt status if it meets any one of the five purposes of Green Belt. 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. This area of land satisfies these purposes. The land north of Leamington is valued Grade 2 agricultural land and should be retained for farming. Also 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.

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. The following additional points are relevant as there was not an option to expand on answers in the relevant sections: (S1) Without the Local Nature Recovery Strategy there is no guarantee that any green or blue corridors identified by SWLP will have a beneficial impact on nature. For this reason we suggest that neither options S1a or S1b are appropriate. It would be better to identify corridors after a strategy has been produced. (S2) Certain types of intensification in town centres should be supported for example the conversion of unused retail property, including upper floors, to provide housing. Green Belt boundary review does not need to happen (from a policy perspective) and should not happen (from an environmental safeguarding and wellbeing perspective). If it were to happen, it should be part of a strategic West Midlands Review rather than a piecemeal exercise (West Midlands Land Commission, 2017). In view of all of the comments above the consultation process should be halted and the parameters of the Local Plan shifted so that Green Belt development is not assumed. The non-Green Belt growth options that were explored in Part 1 of the spatial growth workshops should be prioritised and communicated and the wishes of local residents should be listened to.

Don't target Wilmcote a small rural historic and nature rich village or any other such village to over develop outside of the NDP which village communities advised to you and don't use the rail station such as Wilmcote's and the sustainable transport issue as an excuse to reach housing targets for Birmingham or Stratford.

The concept of the 20 minute neighbourhood, in terms of providing for residents basic local needs and hence reducing the need to travel and enhancing wellbeing is supported; as is the use of the concept as a criteria in comparing options. However, the number of jobs provided within a 20 minute neighbourhood will be significantly lower than will be required to support any new or expanded settlement, which are likely to be in the range of 1 to 2 jobs per home. It is suggested that an economic study, which looks at the spatial locations of these new and existing jobs, both within and outside the area of the Plan, is required as a major input to the analysis of locations for new housing. This would be a key factor in assessing transport, working towards a cost-effective solution for families, and achieving net zero. The plan identifies that the infrastructure required for a new or expanded settlement takes several forms. It is accepted that some of these are not viable at the early stages of a development, however they should be planned at the outset.

the areas south of Warwick, Whitnash and Bishops Tachbrook need protection from mor development as does the area between whitnash and Radford Semele

I am very worried about downgrading greenbelt land. Presumably land was made greenbelt for a reason in the first place and why should this chance for the purposes of building. The importance of nature is preserving natural spaces is increasingly more important in our current society. If anything a green belt should retain its status if it fulfils only one of the criteria.

I am concerned that the Green Belt is not given sufficient weight in the Issues and Options Consultation on the South Warwickshire Local Plan. The Green Belt around the North of Leamington fulfils all of the five stated purposes of Green Belt land. The South Warwickshire Local Plan Process should fully examine all other options, including new settlement options outside of the Green Belt, before starting a study to review Green Belt boundaries in South Warwickshire. For these reasons and several other relevant and valid counter-points made by Councillor Bill Guifford in his letter to WDC, I am opposed to this development and urge all concerned to preserve the purpose and integrity of this valuable Green Belt around North Leamington.

I do not believe that sufficient effort has been spent in active identification of brownfield land for development. Greenbelt must be protected at all costs. It is not true to say that greenbelt development cannot be avoided. The impact on small rural greenbelt villages like Weston under Wetherley would be devastating under some options in the local plan. The scale and nature of proposals are inappropriate. The Climate Emergency is not suitable justification for greenbelt development - in fact, the opposite is true, from a Scope 3 GHG emissions perspective. Development should be prioritised on brownfield sites. It is also unfortunate that there is no option to comment on the review of greenbelt boundaries. 'Moving the goalposts' is not an appropriate approach!

This is all very complicated and difficult to comment on, but assume 'boundaries' means villages etc remain discrete, not ribbons of housing stretching from one village/small town to the next. THis is very, very important. And from what Ihave seen of proposed development areas is just not happening. Every bit of land in my village to next is ear-marked for development.

I strongly believe the South Warwickshire Local plan process should fully examine all other options including nee settlement options outside of the greenbelt before starting a study to review greenbelt boundaries in South Warwickshire. 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. The farmland is high quality agricultural land and makes an important contribution to sustainability and food security.

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. 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. 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. 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

The green belt round Leamington is valued open space used regularly by dog walkers, runners, and families for walks. To lose this space would be o lose the special character and setting of historic Leamington Spa

The plan threatens a coalescence of settlements between Leamington and Kenilworth. It doesn't follow the principle of "brownfield first", unnecessarily building on vital and irreplaceable green belt land. The development on green belt land threatens the biodiversity of the local area.

The Green Belt land north of Leamington fulfils all the five stated purposes of the Green Belt. It is not in line with Government policy to develop the Green Belt. Derelict land and other urban land should be developed as it assists in urban regeneration. The Green Belt land north of LeamingtonSpa is very important as it prevents the merging of Leamington Spa and Kenilworth. Leamington Spa and Warwick have already merged to the detriment of both towns. It is high quality agricultural land should be safeguarded for food security which is very necessary as we have seen by the empty supermarket shelves recently. Many people from Leamington use the footpaths to walk their dogs or to walk with friends. I also notice that a Park and Ride has reared its ugly head again. We have rejected this time and time again. Leamington Spa does not need a Park and Ride. There plenty of car parks and on street parking., Valuable agricultural land will be lost for no good reason. We are also surrounded by HS2 taking up valuable land. It would be very irresponsible if we denied our children and grand children green spaces to enjoy with their families.

Whilst developers will always favour development on green sites, for reasons of cost and profit, future development should be undertaken on brown field sites as a default position rather than on green sites, wherever possible. Particular emphasis should be placed on preserving the green belt not allowing it to be chipped away when suitable brown field sites could be found and would meet needs. Failing to make use of, or to repurpose Brown Field sites is a waste of valuable land resources which, even though more expensive to develop, leads to erosion of green belt and loss of an irreplaceable resource. Further many Green Belt villages do not possess good transport links or facilities and increased development within the green belt will inevitably lead to increased vehicle usage contrary to any desired aim to reduce carbon emissions or maintain biodiversity. Where any development is considered within the Green Belt, it should be a primary consideration that such sites are located proximate to areas of sustainably available employment, to minimise the number of car or other vehicle journeys.

I am very concerned that there is no consultation question for "Issue S6 - A Review of Green Belt Boundaries". This implies that a decision has already been made, despite there being many factors that severely call into question the rationale for the review. For example: 1. Government policy (as per Department for Levelling UP, Housing and Communities letter of 5 Dec 2022) asserts that local authorities are not expected to review the Green Belt to deliver housing. 2. One of the five purposes of the Green Belt is to prevent neighbouring towns from merging. The proposals instigate a merging of the boundaries between areas such as Kenilworth and Leamington; as well as Old Milverton and Blackdown into Leamington. 3. Loss of farmland impacting food sustainability and security. 4. Loss of recreational and health benefits. Therefore all other options to achieve the development strategy should be explored in full before a review of the Green Belt is considered.

Made Neighbourhood Development Plans should be respected. The current inability to deliver the full LMA site because of failure to fund road infrastructure shows a weakness in basing further housing on such need. Delivering it in a location that is already providing widespread connectivity beside trunk roads and rail would seem to provide assurance that such development could be deliverable. The main siting that would seem appropriate is beside the A46 particularly where it is dual carriageway or could easily become one and at locations near to the M40. To the east the Toll Bar development and the new road overpass towards the roundabout that leads to Walsgrave Hospital has created significant through capacity to the A14 and M69 as well as connection into Coventry.

We as a Parish Council are asking why there is no response space for comment on issue S6. It is almost as though Green Belt boundaries are being ignored and the five purposes of the Green Belt wilfully trampled over by all the other development considerations. The Spatial Growth Options all include significant incursions into the North Leamington and Warwick Green Belt flying in the face of maintaining the integrity of villages such as Leek Wootton, Cubbington, Old Milverton and Blackdown. The conclusions of the spatial growth workshops are dangerously flawed in maintaining Green Belt areas have little legitimacy. The Secretary of State for Levelling Up Housing and Communities has asserted that local planning authorities are not expected to use Green Belt to deliver housing and the many constraints, particularly space, around North Leamington and Warwick should rule out any further housing development.

I am specifically opposed to the development of land between weston and Hunningham as this directly affects my village, commute, view and standard of life among other things. When buying in this village we specifically looked for any planning applications for large developments around the area and chose to buy here as this didn't seem to be an option as all of the surrounding land is greenbelt. So to now be proposing developing this is a little infuriating. There are already huge amounts of housing developments around the Leamington area, which are causing traffic and pollution issues. My fear is the area looses its appeal and becomes industrialised to sustain the demand of the expanding population. Trying to sell this proposal as a solution to the climate emergency is farcical, and appears to be a wild approach to creating huge housing estates in more rural locations, with better views etc, purely to elevate the value of the properties once ready to sell-at the expense of the residents that have already purchased on contributed to the economy within these areas.

I am concerned that the council is considering plans to build upon the land bordering Old Milverton Lane on the northern side. This is green belt land which provides a natural habitat for a wide range of wildlife. We should endeavour to protect our countryside for future generations and consider all other options before encroaching on valuable country spaces. I strongly believe that the council should focus on developing brown belt land before squeezing out green belt areas. I believe that the SWLP should fully analyse such alternative options. Green Belt land must continue to provide all 5 of its purposes as suggested by the National Planning Framework.

I am concerned that there is consideration of developing what is currently green belt land, for example, the land on the northern side of Old Milverton Road. None of the options seem to have considered not developing green belt land by focussing only on brown belt land. I believe that the SWLP should fully analyse such alternative options. Green Belt land must continue to provide all 5 of its purposes as suggested by the National Planning Framework.

My comments apply to the proposal to review Green Belt boundaries. 1) I would urge the South Warwickshire local plan process to fully examine other options (including new settlement areas outside the Green Belt) before starting any review of Green Belt Boundaries. This does not (yet) seem to have occurred. 2) Green Belt is protected if it can be shown to meet any single purpose out of five possible options (National Planning Policy Framework). Current issues and consultation appears to propose that all five purposes have to be met otherwise current Green Belt can be reclassified (and hence developed). There is no good reason why South Warwickshire should deviate from National guidelines. 3) Much of the Green Belt comprises valuable farmland. To destroy this at a time when food security is being prioritised seems entirely counter productive and again I would urge other options to be considered.

I am repeating the same text for every question in protest at the unbelievably long-winded process you force on anyone wanting to make a comment. My comment is: As a Kenilworth resident I want to register my dismay at the amount of land that has been earmarked for new housing development. Kenilworth's major asset (the castle) is at risk of losing the various country walks on land adjacent to it. Please try to keep the green fields around the back and towards Chase Lane untouched. The infrastructure of the town is already under pressure - specifically I am concerned about medical facilities, water pressure and extra traffic (Kenilworth's station will be a long walk away from these proposed sites and there very few trains so increased car journeys are inevitable). I am appalled at how difficult it has been to make my point of view (as summarised above). The process is unnecessarily long-winded and impenetrable.

I am repeating the same text for every question in protest at the unbelievably long-winded process you force on anyone wanting to make a comment. My comment is: As a Kenilworth resident I want to register my dismay at the amount of land that has been earmarked for new housing development. Kenilworth's major asset (the castle) is at risk of losing the various country walks on land adjacent to it. Please try to keep the green fields around the back and towards Chase Lane untouched. The infrastructure of the town is already under pressure - specifically I am concerned about medical facilities, water pressure and extra traffic (Kenilworth's station will be a long walk away from these proposed sites and there very few trains so increased car journeys are inevitable). I am appalled at how difficult it has been to make my point of view (as summarised above). The process is unnecessarily long-winded and impenetrable.

Just a general comment that the various councils’ policies should reveal how they will resolve the climate change emergency in relation to the plan