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

I would like to object on the proposed development of the land behind Red Lane, Burton Green (Ref ID 237) for the following reasons:- 1. Limited schooling available places (we had to go to Appeal to get our two children into a local school, both primary and Secondary school) all places offered were out of catchment; 2. Proposed development on Greenbelt which has already been part destroyed by HS2 which has massive impact on nature, such as birds, bats, hedgehogs, deer etc. Habitats for wildlife have already been impacted by HS2 this would destroy more of their homes; 3. Noise and air pollution from the site would be destructive and disruptive for several years; We have just moved from a house that was subject to local development around us that lasted over 8 years. It was excessively noisy listening to diggers 12 hours a day and workmen shouting, playing music etc. The noise plus the dust and dirt was very polluting, the area was often subject to safety issues whereby several children were injured playing near the building site. 4. Red Lane is a country lane, so extra traffic and lack of footpaths will make the area unsafe for our children when leaving the house; the blind bends are a safety hazard which will increase the likelihood of accidents. 5. The development would overlook our house which would affect privacy and security. 6. Drainage systems are not in place in Red Lane as many residents are still using septic tanks and have no gas; 7. Very poor internet access which is not due to be upgraded to fibre before 2030, this is another limited amenity; 8. No local shops in the vicinity, this requires more travel which increases traffic; 9. Overdevelopment of Burton Green which is a small village community which has been subjected to significant development from both HS2 and other local housing developments 10. Road access to this development is very limited; 11. Increase of crime in the area due to being unsecure and limited facilities/amenities for youths. Kind Regards Sharon Skidmore

I wanted to comment on S6 A review of Green Belt boundaries but you do not give the option there to do so. This seems unfair and the starting point from your plan and consultation is that the Green Belt should be developed when surely the Green Belt is there to protect the countryside and should be built upon only if there are are no non-Green Belt options available which is not the case in the district. This proposal runs against the Governments current policy which says that green Belt does not need to be build upon for housing when there are other non-Green Belt site available. The whole plan does not provide option for the Green Belt to be left as Green Belt and this option should also be included, especially as this is the Government policy, particularly in terms of sustainable food production and biodiversity given we are one of the most nature-depleted countries in the world. The Government's policy is to prevent the loss of high quality agricultural land as they are a high level resource for sustainable food production. The National Policy Planning Framework states "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer qualities of land in preference to that of higher quality." This should be taken very seriously given the land to the north and east of Leamington has the highest concentration of ALC Grade 2 Land around Leamington and Warwick.

Protect the Green Belt. Encourage brownfield development. Include intensification in planning policies. Include small development in-fill in planning policies. Use railway lines and by pass roads to create development borders, to prevent unattractive urban sprawl. Keep developers in check, to ensure that the legacy they leave is attractive. Ensure that all development suits its location, for size, style, design and volume. Ensure that there are gains and benefits for the exisiting community, where development takes place. Finally review the needs of the SWLP regularly because it may be that in the future less houses are actually needed. This is due to smaller families, lower birth rates and the effect of obesity reducing average life expectancy!

***Concerning Thresholds*** Whilst very small-scale housing growth in smaller settlements is likely acceptable, the setting of an arbitrary threshold fails to recognise that the same number of houses in two different settlements may have completely different impact. It would therefore be more appropriate for either settlements to be ‘categorised’ and ‘scored’ and/or through the involvement of local Parish Councils (or groups of Parish Councils) individual thresholds agreed. Care would also be needed in areas which have abutting local government boundaries to ensure that settlements are considered holistically and not simply based on parish boundaries – otherwise there is a danger that some locations have a cumulative number of houses that is not in proportion to the overall size. Norton Lindsey is a prime example of this potential problem - the ‘village’ of Norton Lindsey is split between three parishes (Norton Lindsey, Wolverton and Claverdon) and there is the potential that each parish could be considered on its own merits, but the housing all built next to each other in the same ‘village’ – which could mean more houses built than if the village was considered holistically. ***Concerning Boundaries**** All settlements should have identified and agreed ‘boundaries’ determined. These boundaries should reflect the actuality on the ground rather than simply be based on a ‘paper’ review. Care would also be needed in areas which have abutting local government boundaries to ensure that settlements are considered holistically and not simply based on parish boundaries – otherwise there is a danger that some locations have a cumulative number of houses that is not in proportion to the overall size. Norton Lindsey is a prime example of this potential problem - the ‘village’ of Norton Lindsey is split between three parishes (Norton Lindsey, Wolverton and Claverdon) and there is the potential that each parish could be considered on its own merits, but the housing all built next to each other in the same ‘village’ – which could mean more houses built than if the village was considered holistically.

It is important to consider 'actual' boundaries rather than 'paper' boundaries when considering settlements. For example Norton Lindsey as a village consists of three parishes - with one parish Claverdon having its main population centre around 2 miles away. Therefore if plans are put in place at a 'parish' level, it could quite easily see housing for 'claverdon' being built in 'Norton Lindsey' even though it is a considerable difference away.. The plan must holistically consider a settlement not a parishes- appropriate safeguards must be put in place to ensure that a settlement split between parishes does not find itself with 'over-development' because of artificial lines on a map.

1. All other options for housing development should be fully exhausted before considering the "green belt". Once the "green belt" is gone then it is gone for ever. 2. An area's green belt status should be maintained if it meets any one of the 5 purposes of green belt.

The development is expected to demonstrate that they avoid the best and most versatile agricultural land unless the benefits of the proposal outweigh the need to protect the land for agricultural purposes. The agricultural land between Old Milverton and North Leamington is grade 2 agricultural land and the best fields on the farm. It not only grows a wide variety of crops but during the recent pandemic provided recreational space for the local people. This is demonstrated by a huge local response to an appeal in aid of the Air Ambulance as a 'Thank you" to the farmer for use of this space. The sum of £2637 was raised and comments from 171 people included, 'This space has really been a life line in the last year', We have enjoyed walking across the fields so much. This has saved our sanity and on many occasions made us smile even on the worst days. Having access to the countryside on our doorstep has made a huge difference. The diversity of wild life has also been mentioned. This process is flawed. The strategic process is flawed. The objectives 4 and 5 strive for health, well being and environmental protection, yet all of the proposed growth options presume green belt development.

Re Green belt boundary review. any one of the 5 purposes for the Green Belt should be sufficient on its own for maintaining an area`s status as Green Belt. The county has suffered great environmental destruction as a result of HS2- 5 times the amount admitted to by HS2Ltd. We must protect what we have left. Use brownfield sites, tax second home owners to raise revenue for affordable housing. Take the climate emergency seriously, please.

Extensive growth and development in any rural village is inappropriate as has already and is already being seen around South Warwickshire villages. Development must be proportionate and scaled to the context. Design guidelines and contextual design standards are required to prevent the poor quality, cookie cutter style house seen across the country. The new settlement at 'F3 - Land North East of Knightcote' on 'Erratum – 6th February 2023' is not appropriate and has been added late with questionable influence and motive. That area is not suited to development of a new settlement by any sensible consideration against any metric.

We and the Old Milverton and Blackdown parish council are asking why there is no consolation question for issue S6 - A review of greenbelt boundaries. There are plenty of arguments to say why the green belt should be protected and why the North Leamington Greenbelt should be maintained yet this section is presented as a closed case. This is entirely undemocratic.

Consideration is being given to reviewing green belt boundaries. I note that NPPF states, 'Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period. ' It goes on to say 'Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.' Any changes to green belt boundaries would need to follow this advice and to demonstrate that 'VERY special circumstances' or 'exceptional circumstances' exist to justify the change. I recall that in the context of the examination of the current Warwick District Local Plan the council was unable to demonstrate that 'very special circumstances' existed for the release of green belt land and I wonder whether the situation has really changed since then, especially given the importance which the NPPF attaches to the permanence of Green Belts.

Why is there no consultation question on S6. This is a critical issue for many residents and should be presented with a question.

In respect of Wootten Wawen and the surrounding area, development is welcomed in order to bring into the village younger people due to the majority of the current population being more of the older generation. Young families with children will support the viability of Wotton Wawen primary school. Furthermore, having a greater population will also sustain the local businesses in the area. Notwithstanding the above comments, the amount of homes must be limited to a maximum of 50. There must be a careful balance as introducing more homes will also put a strain on the current infrastructure, which includes, but not limited to the following:- - The roads through Wootton Wawen have junctions which have very limited visibility on the A3400, i.e., Pettiford Lane, Pennyford Lane, turning into Wootton Hall. Despite the speed limit being 30 miles per hour, cars drive in excess of this limit and there have been a number of accidents. - The state of the roads in Wootton Wawen are not in good repair. More homes will only result in ‘rat-runs’ being created and will damage those minor roads. - Wootton Wawen has a railway station however, there is no car park which services the station. Whilst it may be anticipated that people living in the village who wish to commute will walk to the station, in practice that will not be the case. Therefore, there will be a build-up of traffic around the station and the surrounding roads causing a disruption to those living near to the station. Furthermore, the roads leading up to the station are narrow roads with junctions which have limited visibility. - There will inevitability be a build up of traffic which will increase the road traffic noise at the busiest of times. - There is no GP surgery in Wootton Wawen, the nearest surgery is in Henley-in-Arden which will increase traffic flow (see above). - Wootton Wawen has flood plains, where more houses will place a strain on the drainage infrastructure This is evident with the increase of homes on Pennyford Lane where at the wettest part of the year, the lane gets flooded. In addition to the above comments, the following should also be taken into account: - Wootton Wawen has a great deal of history. Having a large development will have an effect on the setting of the great deal of listed buildings within the village. - The Green Belt status of Wootton Wawen. A larger development will only decrease the wildlife areas in the village.

I think there should be a consultation question for Issue S6 – A review of Green Belt boundaries. There is much to say about why Green Belt land should be protected and why the North Leamington Green Belt should be maintained yet this section is presented as a closed case. I also question why various contributing studies have been awarded to consultants that are not locally based. This would suggest that local knowledge has not been sufficiently employed in compiling these studies. Furthermore, this consultation document sets out the local authorities' "desire to desire to grow the South Warwickshire economy" yet commissions contributing work from companies based outside the area!

Why is the option to discuss the north Leamington green belt seemingly closed? The advantages of keeping this area as undeveloped remains an important question. There are trees presently on the green belt that are on the ancient tree register. There are roosting and breeding trees for Barbastelle bats at their most northerly zone. There are farm ponds that house great crested newts and there are regular sightings of red kite. The biodiversity of these areas whilst within agricultural land are not to be ignored and the green belt is already fragmented as it is. Protection of these areas must not be over shadowed with the perceived need for cramped housing estates which will destroy vital habitats and reduce the enjoyment of these spaces down to dog walking areas.

As there is no specific comment box seeking comments on S6 The Review of the Green Belt Boundaries, I therefore comment here. The Government has stated that LPA’s are not expected to review the green Belt to deliver housing which is now echoed within the draft NPPF. Both existing and latest draft Green Belt policy protects against changes to the Green Belt. Changes should only be considered if exceptional circumstances exist, to justify a change, and then only after fully examining all other reasonable options. This has not been fully examined with only workshops being held, and the non-Green Belt options being discounted. This results in all 5 options including Green Belt land. There should be options excluding any Green Belt for consultation.

S6 – Review of Green Belt boundary • The National Planning Policy Framework, 2021 (Sec 13: Protecting Green Belt land, 137-143.) explains that the Government attaches great importance to Green Belt, adding the essential characteristics of Green Belts are their openness and their permanence. Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. o There is no justification here, and no such exceptional circumstances, where there exist brownfield sites and/or other underutilised housing opportunities within existing settlements. o When (re-)defining Green Belt boundaries, plans should define boundaries clearly, using physical features that are readily recognisable and likely to be permanent. The proposed sites in Kenilworth South have no readily recognisable physical features to outline any change in land classification. o Removing Green Belt land undermines the goal of tackling climate change by removing green field land and with it high quality farmland and biodiversity, and increasing the use of the car and associated emissions (particularly as in Kenilworth, the broad locations do not perform well in terms of public transport, especially Kenilworth South). o It will also undermine the objective of coalescence, particularly in relation to the urban sprawl from Coventry to the North of Kenilworth and Leek Wootton (and onto Warwick) to the South. o Green Belt land in Kenilworth South is UAA, regularly producing barley. A product which saw a national decrease in production by 4.2% during 2022. Green Belt land which has soils rich enough for food production should be protected. • The last four paragraphs of section S6 provide some fine words regarding the future of the Green Belt which we support. However, earlier in the section there is a strong hint that Green Belt land adjacent to existing settlements is inhibiting development which otherwise meets environmental and sustainability targets. This is wrong generally within Kenilworth, given the role that the Green Belt plays here in particular, and especially in relation to Kenilworth South. Release of this land would undermine environmental and sustainability targets in terms of Accessibility (see SA11) and in terms of impacts on biodiversity (see SA3) and landscape and cultural impacts (SA4 & SA5).

i feel that the Local Plan process should examine all possible options before looking at encroaching on green belt - so important for all the reasons you list- bio diversity above all, and the need to maintain the distinctive character of our historic towns. The green belt was set up for a purpose and it should be allowed to continue with that for all our benefits. i am also worried about the infrastructure implications on roads and services.

I object most strongly to the council's proposal to review the current Green Belt boundaries in North Leamington Spa. Building on Green Belt in this area would result in the reduction and closing of the green spaces currently separating Leamington Spa from the neighbouring city, town and villages of Coventry, Kenilworth and Leek Wootton. The loss of countryside between Leek Wootton, Kenilworth, Coventry and Leamington Spa would be detrimental to the setting and special character of North Leamington Spa. The Green Belt in this area currently comprises of high quality farm land which also supports a variety of wildlife. All efforts should be made to redevelop other urban sites or non Green Belt land before a review of the current Green Belt boundaries are contemplated. There are significant areas of non Green Belt land between South Leamington Spa and the M40 which should be used to address any local housing needs before revising the current Green Belt boundaries. Building on land to the South of Leamington Spa, where new transport infrastructure can also be built would also impose far less impact on the existing transport infrastructure of Leamington Spa. Building to the south of Leamington Spa would also place populations closer to local areas of employment, retail and the national motorway network. With these other options being available I do not consider that there are special circumstances which merit the revision of the current Green Belt boundaries. The current boundaries were identified for very sound reasons. I value my local community, countryside and green spaces. They must be preserved for future generations. I trust the council will continue to protect the current Green Belt boundaries particularly when other more suitable alternatives are available.

As there is no specific comment box seeking comments on S6 The Review of the Green Belt Boundaries, I therefore comment here. The Government has stated that LPA’s are not expected to review the green Belt to deliver housing which is now echoed within the draft NPPF. Both existing and latest draft Green Belt policy protects against changes to the Green Belt. Changes should only be considered if exceptional circumstances exist, to justify a change, and then only after fully examining all other reasonable options. This has not been fully examined with only workshops being held, and the non-Green Belt options being discounted. This results in all 5 options including Green Belt land. There should be options excluding any Green Belt for consultation.

Housing development on green belt land that could lead to coalescence of existing settlements must be avoided. I am thinking particularly of proposals for development to the North of Kenilworth that could so easily lead to coalescence with Coventry. I understand the proposals regarding development close to railway lines, in this case it would be the HS2 line curently under construction, but housing development close to such a line may not be wise in view of the potential for ground shock waves emanating from high speed trains.

I don't understand why there isn't a consultation question for S60 around developing on greenbelt. Surely this is a big questions that needs to be consulted on?

Green belt status should be maintained when it meets any one of the purposes of green belt land as set out in the NPPF. In order to get around these regulations developers or other agencies concerned to develop on the green belt will sometimes draw attention to areas where green belt land has been incrementally affected by piecemeal development that goes under the radar of planning regulation at any given. This practice is deliberate strategy for removing protected land from the green belt. Where this has occurred it should be stopped, it certainly should not provide justification for further development. The NPPF states green belt status is maintained if any one of the five criteria are met. The green belt in Milverton and Blackdown meets at least four of these - preventing sprawl, preventing the merger of distinctive communities in towns and villages, safeguarding the countryside and protecting the historic nature of towns and villages in Warwickshire. There is no legitimate case for not preserving green belt status in this light. Added to that these greenbelts are essential to the health and well being of local communities - both their physical and mental health (with all the benefits that brings more broadly to hard-pressed council budgets). They are heavily used by the local communities for walking and fitness, also for social purposes (e..g dog walking, children playing). This has been the case for years but the recent lockdowns associated with the covid-19 pandemic showed just how important the green belt was in this respect. When schools, gyms, sports facilities and other forms of social life were closed down the green belt became an essential part of the local community's coping strategy. If we are supposed to be 'future-proofing' our towns and cities from pandemics then green belt development would be a retrograde step in the light of our recent history. It goes without saying (but perhaps it needs to be said anyway) that ALL other options should, as a matter of necessity and law be examined and prioritized before green belt development is even considered. Intelligent planning frameworks should not legitimize developer-led sprawl with the figleaf of affordable housing or sustainability (both of which are often more about developer coroporate branding than any understanding of how built environments work). Intelligent planning should work with the grain of historical communities rather then degrade them - this means understanding that you cannot simply isolate given areas for development without having broader effects that go beyond the area of development themselves - but are less immediately visible. Our built environment is a complex system and simple, short-term localized solutions to complex problems (such as housing), such as changing green belt boundaries to permit more development, will not provide lasting solutions. The green belt is a precious resource and once it is gone, it is irretrievable, creating new problems for existing communities, while the larger problems remain.

It is inappropriate that there is no consultation question for Issue S6 - A review of Green Belt boundaries. No Exceptional Reasons have been presented as to why Green Belt land is proposed for development land. Green Belt land should be protected, and the North Leamington Green Belt should be maintained yet this section is presented as a closed case. I understand that the council body, councillors and officers within it may see financial benefits from turning over green belt to housing developers. Such a strategy is flawed, was shown to be flawed in the previous local development plan, and will be shown again to be flawed if the council seeks to persist with this.

THERE IS OUTLINE PLANNING PERMISSION TO FURTHER DEVELOP THE LONG MARSTON / MEON VALE DEVELOPMENT. THE CONGESTION IMPACT ON STRATFORD UPON AVON IS A REAL CONCERN AND SUBSEQUENT DEVELOPMENT MUST BE CONDITIONAL ON APPROPRIATE HIGHWAY IMPROVEMENT BEING IMPLEMENTED. DEVELOPMENT OF STRATFORD UPON AVON IS CURRENTLY FOCUSSED ON THE WEST, EAST AND SOUTH OF THE TOWN. THERE IS A REAL OPPORTUNITY TO DEVELOP TO THE NORTH (CLOSE TO STRATFORD PARKWAY) - WHILST THIS WOULD NECESSITATE DEVELOPMENT ON GREEN BELT (WHICH I WOULD NORMALLY OPPOSE) THIS IS A STRATEGY I WOULD SUPPORT

Issue S6 - A review of the Green Belt Boundaries. There is much to say about why Green Belt land should be protected and why North Leamington Green Belt should be maintained yet this section is presented as a closed case.

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 Warwichshire. An area should maintain its Green belt status if it meets any ONE of the five purposes of Green belt as defined int he National Plannning Policy Framework. It appears from reading the literature provided by the Council that it has determined that studies are valid in areas that no longer meet all FIVE of the Green belt purposes, for removal from the Green Belt. I support the Old Milverton Parish Council's challenge to the development and would like to raise my concern about why there is no specific question in the consultation for Issue s6 A review of Green Belt Boundaries. There is so much to say about why the North Leamington Green Belt should be maintained yet it appears to be a closed matter. I strongly object to this position taken by Warwickshire Council for the following reasons: 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. 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. 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. 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. 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. 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. 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.

Green Belt (issue S6) with specific reference to the Land at Blackdown, north of Leamington Spa (REFID 174 – loss of 69 acres of Green Belt agricultural land for Housing/Residential). The proposed development on 69 acres of agricultural land which currently provides the green buffer to the urban area to the north of Leamington Spa is a significant departure from the over-arching principles of the current local plan which protects Green Belt. The key issues with this development are that, beyond the loss of an important area of wildlife and agriculture which represents the character of the area to the north of Leamington Spa, it also fails to represent a sustainable development proposal. The site lacks the access to amenities provided to the South of Leamington Spa, which has already seen a significant increase in residential provision and where significant numbers of homes remain available therefore raising questions over the need for further housing at the expense of such an important area. The land to the north of Leamington is more restricted in its connectivity to key infrastructure such as the station and major shops and will drive significant traffic through the town centre which does not have the capacity for such a significant increase. Over 1000 homes are suggested for this land (174) which will produce a significant increase in the resident population and exceed the available places in the local schools which are all at or very close to capacity OR will require a significant number of residents to attend schools to the south of the town, again creating a significant impact on the traffic through the town centre. With such a significant level of housing remaining available (New builds Heathcote, Warwickshire (newhomesforsale.co.uk) ) to the South side and numerous other non-Green Belt sites remaining available it is clear that the loss of the greenbelt land in this location, particularly when combined with the loss of Greenbelt due to HS2 which is in close proximity, thereby creates a drastic extension to the urban area and completely alters the character of the area. With the proximity of the HS2 development area, this area of land creates a important green barrier to further encroachment into the Green Belt and wider countryside and the merits of the site for housing development and necessity are highly questionable as it appears the site is not well supported by transport, amenities, creates wider issues such and schools and other public service provisions particularly where housing supply still appears sufficient.

Please note this website process is not up to standard, and has put me off from submitting questions. This is not user friendly enough to be considered a fair and meaningful process - the help instructions are vague, I have comments from a previous consultation populating fields, which have prevented me from answering some individual questions. I therefore am submitting thoughts here. 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 Warwichshire. An area should maintain its Green belt status if it meets any ONE of the five purposes of Green belt as defined int he National Plannning Policy Framework. It appears from reading the literature provided by the Council that it has determined that studies are valid in areas that no longer meet all FIVE of the Green belt purposes, for removal from the Green Belt. I support the Old Milverton Parish Council's challenge to the development and would like to raise my concern about why there is no specific question in the consultation for Issue s6 A review of Green Belt Boundaries. There is so much to say about why the North Leamington Green Belt should be maintained yet it appears to be a closed matter. I strongly object to this position taken by Warwickshire Council for the following reasons: 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. 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. 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. 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. 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.

It is regrettable that there is no option to respond to issue S6, namely the review of green belt boundaries. As per my other answers, protecting the green belt is important to keep the separate identity of distinct settlements and prevent Leamington being subsumed into Greater Coventry, as well as the need for recreational space for residents in open nature.