Issue and Options 2023

INTRODUCTION 1.1 Barton Willmore, now Stantec is instructed by Caddick Land, part of Caddick Group, to prepare a representation to the South Warwickshire Issues and Options (Regulation 18) Consultation (‘the Local Plan’), including relevant documents within the evidence ba se. 1.2 This representation follows the structure of the Local Plan and seeks to respond to the questions posed within the Document, where relevant. 1.3 Caddick Land have a development agreement on the identified site off Warwick Road, Leek Wootton, adjacent to the south-eastern boundary of the village. The Site comprises two parcels of land (A and B) which are separated by Hill Wootton Road. 1.4 The Site is being promoted for residential-led development for up to 200 dwellings 1 , including plots to be available to self-builders, a proposed community use/mobility hub, land to facilitate the expansion of All Saints Primary school public open space and landscaping. This will include the provision of 10% biodiversity net gain. 1.5 Caddick Land are a team with over 30 years experience in development and construction, helping landowners to realise the full potential of land through development for housing, renewable energy and commercial or mixed use schemes. 1.6 Caddick Land’s mission is to deliver high quality, desirable and sustainable developments, that provide long term benefits and a positive legacy. 1.7 Accompanying this response to the Issues and Options Consultation, is the following material: - Vision Document (Appendix 1) - Green Belt Assessment (Appendix 2) - Highways Note (Appendix 3) - Sustainability Appraisal Compliance Review (Appendix 4) 1.8 Caddick Land welcomes the opportunity to provide a response to the Local Plan consultation and looks forward to engaging with the Council further in respect of residential matters within South Warwickshire. 11.0 LAND OFF WARWICK ROAD, LEEK WOOTTON Site Description and Context Site Description 11.1 The Site is situated adjacent to south-eastern boundary of Leek Wootton, which is identified as an ‘Large Village’ within the South Warwickshire Local Plan: Urban Capacity Study (2022). The Site comprises two parcels of land (A and B) which are separated b y Hill Wootton Road. 11.2 The northern parcel of land is located between the eastern edge of the village, between ‘The Hamlet’ (road name) and the A46, and comprises agricultural land which is bounded by a wooden palisade fencing, residential properties and existing vegetation. The total area of the northern parcel equates to 1.84ha. 11.3 The larger portion of land to the south of Hill Wootton Road is currently used for agricultural purposes and has a total area of 18.21ha. The Site is mostly bounded by trees and hedgerows, either adjacent to the A46 Warwick Bypass or to the rear of existing properties located on Warwick Road. Internally, the land is sub-divided by intermittent hedgerows which have been breached to provide access into adjacent field parce ls. Context 11.4 There are semi-detached and detached residential properties to the west of the Site, located on Warwick Road. Warwick Road is the main road which runs through the village. The road is bounded by hedgerow planting and mature tree planting partic ularly to the south where Warwick Road connects with the junction onto the A46. This planting provides some physical and visual separation from the road corridor although there are views into the internal fields of the site as the road is slightly elevated. 11.5 The closest bus stop is located on Warwick Road, immediately adjacent to the proposed site access. The X16 bus provides a service from this bus stop which runs from Kenilworth and Warwick to Stratford and vice versa. 11.6 Leek Wootton also has accessibility to the IndieGo PLUS service, where users have the ability to book a bus journey between 6am-7:30pm. This service has been considered by Warwickshire County Council to be an improved service compared to the superseded Number 16 service, due to its efficiency and bespoke nature. The Site is also within a reasonable travel distance to both Kenilworth Railway Station (to the north) which is approximately 3.7km away from the Site whereas Warwick Railway Station (to the south) is approximately 3.6km away. To the south of the site there is a roundabout junction with the A46 which connects the village and Warwick Road to the wider road network. This junction is well landscaped, and the tree and shrub planting in this location has matured to provide the site with a high degree of enclosure from the south. 11.10 Leek Wootton is served well by a comprehensive highway network which provides access to the wider areas such as Warwick and Leamington Spa via the A46 (south) and Coventry Road and Kenilworth via Warwick Road. 11.11 The western side of the carriageway on Warwick Road is served with an advisory cycle lane which starts at the Warwick Road/Warwick Bypass/ B4115/ Coventry Road gyratory and ends on approach to Leek Wootton. A section of the cycle lane crosses on to the shared use facility to the southern end of Warwick Road which forms part of the NCN Route 52. 11.12 We are aware that there are two active planning applications on land at the Former Woodcote Police HQ (W/22/0465 and W/22/1877) for 83 dwellings. The Police HQ was released from the Green Belt and allocated for 115 dwellings under the current Local Plan (Policy DS22). Constraints and Opportunities 11.13 The adopted Local Plan Proposals Map confirms that the Site is located within the Green Belt, although the site is heavily influenced by its surrounding context, including residential and road infrastructure. 11.14 The Site is entirely located within Flood Zone 1 (low probability) of flooding; land which is assessed as having a less than 1 in 1,000 annual probability of flooding from rivers and seas. 11.15 The Site does not form part of a conservation area, with Leek Wootton Conservation Area being located 225m to the west. However, this is screened from the Site by the existing properties situated both along Hill Wootton Road and Warwick Road. The Site is therefore not considered to fall within the setting of the Conservation Area. There are also a nu mber of Listed Buildings located within Leek Wootton, however, again, these are not located within the immediate vicinity of the Site, as set out below: • The Cottage - Grade II (approximately 320m away from the Site); • 84, Warwick Road - Grade II (approximately 345m away from the Site); • Church of all Saints (Grade II (approximately 445m away from the Site); • Wootton Paddox - Grade II (approximately 520m away from the Site); • Reading Room Cottage - Grade II (approximately 455m away from the Site); • The Rock - Grade II (approximately 475m away from the Site); • Holly Cottage - Grade II (approximately 585m away from the Site); • The Old Post House - Grade II (approximately 510m away from the Site). 11.16 There are opportunities to provide routes through the proposed development Site which would essentially enhance both the existing pedestrian and cycle access through and around the Site. Planning Policy Designations 11.17 The Warwick District Local Plan 2011-2029 was adopted in September 2017. As mentioned previously, the Site is located within the designated Green Belt which is subject to Policy DS18. The Policy confirms that “The Council will apply national planning policy to proposals within the green belt” . 11.19 The Site currently falls outside of the village boundary. 11.20 There is an area of land towards the northwest boundary (Allocation H37 9 ) which is identified as a Housing Allocation for 5 dwellings (Local Plan Policy DS11) and an allocation for 115 houses at the Former Police HQ, north-east of the site (Allocation DS22). There are currently two live planning applications for the former Police HQ site, both on exactly the same site area for 83 dwellings. Leek Wootton is therefore unlikely to be subject to the level of growth previously envisaged. Net Zero Carbon Development Plan Document 11.21 The Net Zero Carbon DPD forms part of the Council’s ambitious Climate Emergency Action Plan which aims to ensure that new buildings do not continue to impact on climate change. The DPD addresses climate change and sustainable construction in detail than the existing policies and if adopted will impose standards on developments to meet this council’s target of net zero carbon or as close as possible by 2030. This document was submitted to the Planning Inspector in October 2022; the examination hearings are expected to commence March 2023. Leek Wootton and Guy Cliffe’s Neighbourhood Development Plan 11.22 The Leek Wootton and Guy Cliffe’s NDP was adopted in May 2018 and forms part of the Development Plan for Warwick District. The NDP enables local communities the power to develop a shared vision for their neighbourhood and shape the development and growth of their local area. The planning policy framework supports the changing role for existing facilities such as the Village Hall and Sports Club, for instance by providing space and opportunities for a community led shop / café / internet facility. 11.23 Since the 1970s/80s there has been little physical change, but because of Leek Wootton’s central location between Birmingham, Coventry, Warwick, Leamington Spa and Kenilworth properties have become much sought after and it has become very much a ‘commuter village’ which has led to the loss of village shopping facilities. The Parish Plan consultation demonstrated local support for a village shop, but the economic viability of such a proposal, having regard to the proximity of other facilities, is problematic. However, a community run ‘shop’, providing a range of local services such as broadband, a café etc . may be an alternative option, if supported by the Parish Council and other volunteers 11.24 Policy LW10 ‘Supporting a Local Community ’Hub’ Facility in Leek Wootton’ aims to improve local facilities by redeveloping the sports club building, investing in playing pitches, providing provision for allotments and recreational spaces and other communit y uses such as a village shop/ café. 11.25 It is evident that there is now a clear demand for community facilities in Leek Wootton. The Site and its extant is large enough to accommodate a number of dwellings and support future local facilities. Landscape and Visual Impact 11.26 A Landscape and Visual Technical Note was produced in November 2022 by Aspect Planning Limited which provides landscape and visual input in relation to the potential of a residential development on the Site. This Note is included at Appendix 1 to this Representation. 11.27 The Note identifies that the Site is visually contained from the surrounding landscape by the highway infrastructure to the east (A46) and the elevated ground to the west. The surrounding landscape also contains robust vegetation structure of mature tree planting and hedgerows associated with field boundaries, historic listed gardens, residential gardens, and highways embankments. 11.28 In visual terms, the Technical Note identifies that there is good potential to enhance the existing landscape structure to reinforce an already high degree of visual containment and that the Site has capacity to accommodate a well-considered and site responsive residential development in visual terms. 11.29 Lastly, the Note includes a Site-specific assessment of the Site’s contribution to the five Green Belt purposes, as defined within the NPPF, and the potential implications upon the Green Belt as a result of developing the Site. Purpose A) To check unrestricted sprawl of large built-up areas • The A46 dual carriageway is considered to form a prominent and defensible boundary within the Site’s localised landscape setting to the east. • Development within the site would be well contained by this feature, which would act as a permanent and enduring form of constraint to any future potential development extending further to the east and south. • MINOR CONTRIBUTION. Purpose B) To prevent neighbouring towns merging into one and other • The Site does not form part of any strategic gap between settlements and development within it would not result in the merger of any neighbouring towns or built-up areas. • NO CONTRIBUTION. Purpose C) To assist safeguarding the countryside from encroachment • The Site is well contained by the permitter highway routes and robust treelines a nd hedgerow planting, which establish a compartmentalised character, ensuring that future development within it, would not be perceived extending out into the wider countryside. • MODERATE CONTRIBUTION. Purpose D) To preserve the setting and special characte r of historic towns • Leek Wootton is not a historic town. Whilst there is no definitive position on this point, this purpose is generally accepted as relating to very few settlements in practice. In most towns there already are more recent developments between the historic core, and the countryside between the edge of the town. Generally, only relates to sites where the development will alter the character of an established historic core, or impact on views to / from it. It is not to be confused with simply developing on the edge of a settlement • NO CONTRIBUTION. Purpose E) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land • All land within the Green Belt is considered to contribute equally to this purpose. Overall, the Landscape and Visual Technical Note considers that the Site only makes a minor contribution to the purposes of the Green Belt (as defined within the NPPF para graph 138) and in landscape and visual terms development within the Site would not undermine the integrity of the wider Green Belt designation. Highways and Access 11.31 The Southern land parcel is currently accessed from Hill Wootton Road at its northern boundary and Warwick Road at its western boundary. The northern parcel is also accessed from Hill Wootton Road at its southern boundary. All three of these accesses are f or agricultural purposes. The Site is not accessible to the public. 11.32 A Highways Promotional Report has been produced by PJA (January 2023) in order support the promotion of the Site. 11.33 A suitable access point to the southern parcel is proposed off Warwick Road. A second access to the northern parcel is proposed off Hill Wootton Road. The speed limit of both Warwick Road and Hill Wootton Road is 50mph therefore it is suggested that a reduction to 30mph speed limit should be considered, though this is not required to deliver a safe access to the site. 11.34 Section 5 of the Promotional Report sets out predicted trip generation based on a quantum of 250 dwellings, although the Indicative Concept Plan described below only includes approximately 200 dwellings. This ‘worst case’ approach seeks to ensure that vehicle movements can categorically be accommodated within the local highway network. Table 5 - 2 shows the highest trip rates enter/exit the Site during the hours of 08:00-09:00 (138) whereas Table 5-5 shows the second highest trip rates occur between the hours of 17:00- 18:00 (134). 11.35 Taking into account the existing volume of traffic passing through the Warwick Road/ A46/ B4115/ A429 junction, the projected increase in vehicle flow resulting from the development is considered to be modest, but appropriate consideration would nonetheless be given at planning stage as to the precise impacts on the surrounding highway network through appropriate modelling. This would determine whether any mitigation would be required. 11.36 The Site is well placed to benefit from an existing network of active travel links, public transport services and access to the local and strategic highway networks, as well as existing local facilities. It is accordingly recognised that the Site presents the opportunity for potential improvements to pedestrian/cycle access within the wider area. Planning obligations and contributions which arise as part of any future development on the Site could assist in: Pedestrian and Cycle Connectivity: • Local improvement with Leek Wootton: o Potential improvements to the existing provision along site frontages. o If required, general improvements through Leek Wootton village with the potential to include relevant traffic management to ensure conditions for pedestri ans and cyclists are appropriate along with footway improvements. o Potential enhancements to the crossing facility between the eastern and western sides of Warwick Road at its southern end where it forms a junction with the A46 and links to the existing shared use facility. • Wider improvements: o Subject to viability, contributions towards wider aspirations such as the LCWIP route (i.e. Kenilworth to A46 route). Highway Network - To be determined through modelling: • Wider improvements: o Subject to viability, contributions towards wider schemes identified through the Warwick District Infrastructure Delivery Plan (depending on outcomes of traffic modelling). o Overall, the Promotional Report considers that the Site could be developed for approximately 250 dwellings, notwithstanding the submitted Concept Plan which seeks to promote the Site for approximately 200 dwellings. The outline enhancements considered would also be to the benefit of existing users and contribute towards wider aspirations. Concept Plan 11.38 An initial Concept Plan has been provided as part of the Vision Document which is included at Appendix 1 to this Representation, which demonstrates the potential development of the Site. At this early stage it has sought to build on the opportunities identified on the Constraints and Opportunities Plan. On this basis the concept plan has: A proposed delivery of up to 200 dwellings within 20.05ha of developable land, including plots for self-build homes. • Medium density housing (25 dwellings per hectare) would be located towards the northern portion of the Site whereas low density housing (20 dwellings per hectare) would be located towards the central portion of the Site. • A parcel of land towards the rear of the existing All Saints C of E Academy School is to be retained in order to allow the expansion of the primary school premises. • Land adjacent to the site access off Warwick Road is reserved for the provision of a community use/mobility hub. • Public open space is to be retained to the south of the Site for both recreational purposes and delivering biodiversity net gain (minimum 10%). • Open space is retained along the whole of the eastern boundary and is to include planting to provide screening from the A46. • Site boundary vegetation and wider green infrastructure will be retained and enhanced where possible. Planting will use locally native species like Oak to maximise biodiversity gains and increase the connectivity between existing habitats off site. • An indicative primary access/ route is proposed from Warwick Road in addition to a secondary access off Hill Wootton Road. • Design influences have been drawn from the neighbouring developments along Warwick Road and Hill Wootton Road regarding design, density, general layout and material considerations. 11.39 It is important to Note that the client is prepared to work with both the Local Planning Authority and the local residents to help deliver this development, and shape it in a way that maximises benefit to the local community. Summary 11.40 Whilst the emerging Local Plan is still at Regulation 18 stage, Caddick Land supports the approach to the proposed development strategy and Site options – particularly in relation to the need for Green Belt Review, in order to accommodate housing need. Caddick Land is also fully supportive of reviewing Sites within the Green Belt as part of that process to ensure that the broadest range of possible options to deliver the homes needed for communities across the South Warwickshire Local Plan area are fully considered to ensure that sustainable patterns of development are achieved. Furthermore, Caddick Land support that the Councils have acknowledged and recognised within the Urban Growth Study 10 that Leek Wootton is identified as a main settlement. It has also been demonstrated within this Representation that Leek Wootton is a suitable location for growth within the majority of Growth Options. 11.41 In addition, the Site is in single ownership and can come forward immediately. 11.42 When considering the Green Belt, the Site is considered to make a minor contribution to its five purposes. The Site’s revised south-eastern boundary forms a logical new, defensible Green Belt boundary, comprising an established vegetation feature along its entirety, with the A46 beyond to restrict the potential for future development. The Site is very well contained within the local area, and with careful mitigation, any potential visual impacts can be avoided/ designed out. 11.43 The Site is capable of delivering up to 200 dwellings, including self build plots, along with additional community facilities and extensive open space. The proposed access arrangements are acceptable for a development of this size. The provision for pedestrian and cycle routes would enable the Site to connect with the surrounding area and proposed public open space to the south. 11.44 In line with both Planning Practice Guidance and NPPF, it has been demonstrated that the Site is deliverable due to it being: • Suitable for development - The Site, aside from its Green Belt location, it has no constraints which restrict its development. • Available for development - The Site is within single ownership allowing for its holistic development and avoiding any issues with conflicting landowners. • Achievable for development - Caddick Land considers the Site to be economically viable and can be delivered promptly due to its medium scale – in line with paragraph 69 of the NPPF - which recognises the importance of such Sites making an important contribution to housing supply.

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Caddick Land broadly supports in principle the Vision set out within Chapter 3 which stipulates ‘The Vision is to meet South Warwickshire’s sustainable development needs to 2050, while responding to the climate emergency. Where appropriate and agreed , this could include unmet need from neighbouring authorities. The Plan will provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time’. 2.2 In particular, Caddick Land supports the identification of the potential to meet unmet need from neighbouring authorities. However, the scale and distribution of this need should be agreed through the plan making process. This vision should accordingly evolve and become more specific, once the detail surrounding the unmet need is established. Clarity should also be provided in respect of what is meant by ‘Warwickshire’s sustainable development needs’ which is currently absent. 2.3 Similarly, the Strategic Objectives set out to address the Vision are also broadly supported, however further detail is required. 2.4 Caddick Land supports Strategic Objective 2 (Providing infrastructure in the right place, at the right time) whereby infrastructure is required to support growth in new homes, in o rder to fully support the community of South Warwickshire. Strategic Objective 2 contributes towards achieving sustainable places. However, the Objective outlines that infrastructure will be secured through new development, however further work is required to ensure sufficient evidence is available to demonstrate what infrastructure is needed, in what geographical location, the timescales for delivery and sources of funding. 2.5 Strategic Objective 4 (Delivering homes that meet the needs of all our communitie s) acknowledges the need for further housing within South Warwickshire, and that a variety of house types, mixes and tenures are required in order to fulfil wider needs, also contributing towards sustainable development. Whilst this is supported by Caddick Land, it is submitted that reference should also be made to meeting the unmet needs of neighbouring authorities, in order to align with and support the delivery of the Vision. 2.6 Strategic Objective 5 (Contributing towards Net Zero Carbon Targets) seeks to ensure that new development does not cause a net increase in carbon emissions. It goes on to state that every opportunity should be taken to reduce existing carbon emissions and mitigate against climate harms. This Objective is considered to be onerous and beyond the scope of national policy. It should be made clear that development should reduce carbon emissions where possible, and mitigate in order to reduce impact further, to contribute towards achieving Net Zero Carbon Targets. At present, it is unrealistic to state that all new development should not cause a net increase in carbon emissions, and would impact upon development opportunities, restricting both the development of opportunities for jobs (Strategic Objective 3) and Delivering Homes that Meet the Needs of all our communities (Strategic Objective 4). 2.7 Overall, the Councils need to ensure the Strategic Objectives achieve a collaborative approach together to achieve the wider Vision and that they do not conflict with one another. As such, Strategic Objectives 2 and 5 need to be considered as part of a wider context, such as realistically achieving Strategic Objective 4. In this regard, Caddick Land acknowledges the movement towards net zero carbon, minimising carbon emissions and the need for the provision of infrastructure, however, the Councils need to ensure that these objectives do not impact upon the deliverability and viability of otherwise sustainable development. 2.8 The Strategic Objectives should also clearly set out how they will meet South Warwickshire’s sustainable development needs, in conjunction with contributing to meeting unmet needs of neighbouring authorities and be clear as to what these needs are.

The HEDNA for Coventry and Warwickshire says it provides evidence about how many jobs should be created by 2050 and how many homes would be needed to house those workers (page 25). The SA provides an evaluation of the different spatial options for growth, concluding that all options tested would increase the volume of housing. However, in terms of the level of growth the SA has only tested two options for housing numbers (page 128). Option I uses the HEDNA trend-based projections point to a need for 4,906 dwellings annually across the whole sub-region with 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum needed in Warwick. Resulting in a combined total of 1,679 per annum. Option II uses the Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire, but with 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum needed in Warwick. Resulting in a combined total of 1,239 per annum. 3.2 The South Warwickshire Local Plan should be more ambitious with its housing numbers and the SA process should include an option of a higher level of housing. As described elsewhere within this Representation, housing growth should be significant elevated if both Councils are to even come close to meeting the level of affordable housing need identified within the HEDNA. This also does not include the provision of housing to meet unmet need arising from within neighbouring authorities. 3.3 As set out in the NPPF, the determination of the minimum number of homes needed should be informed by a LHN assessment using the Government’s standard methodology unless exceptional circumstances justify an alternative approach (para 61). The Government’s standard methodology identifies the minimum annual LHN, which is only a minimum starting point. This is not a housing requirement figure. The Government’s objective of significantly boosting the supply of homes set out in the NPPF remains (para 60). 3.4 Further comments in respect of the Sustainability Appraisal are included within the Sustainability Appraisal Compliance Review, included at Appendix 4 to this Representation.

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Land at Leek Wotton is not dependent on any infrastructure that might be so substantial so as to warrant safeguarding.

Viability and deliverability are key aspects of the Plan, without which the Vision and Objectives cannot be met. The Consultation Document identifies that: ‘all of the sites considered for development as part of the growth strategy will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment (HELAA) to assess their availability, suitability and viability for development. Additionally, an Infrastructure Delivery Strategy and associated viability assessments will be undertaken as the Local Plan progresses to ensure that what is put forward as a preferred development strategy is both deliverable and viable’. 3.7 Caddick Land submits that this work should be undertaken as a priority, ahead of and to inform the next stages of the Part 1 Local Plan. Considerations relevant to viability and deliverability should be considered at the earliest stages of plan-making, to ensure that any allocations identified are viable and deliverable. This includes identifying infrastructure requirements associated with the proposed growth strategy as part of the process of preparing the evidence base and should be made clear in any forthcoming consultation.

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Q-S1 Caddick Land supports the assertion in the Consultation Document that the SWLP will take a proactive approach and seek to identify its own ‘Green Corridors’ across the plan area in advance of the Local Nature Recovery Strategy, in line with Option S1a. The Consultation Document suggests that doing so would allow Strategic Green and Blue corridors to ‘inform the growth strategy’. Whilst this is agreed, determining Strategic Green and Blue corridor s in advance of the Local Nature Recovery Strategy being produced should ensure that the corridors and growth strategy do not conflict with one another. Including these corridors within the Local Plan also ensures that they are appropriately consulted upon against the statutory tests for plan-making. 3.9 Caddick Land reserves the right to comment upon any Strategic Green and Blue corridors identified within future iterations of the Plan. Any such corridors such be based on proportionate evidence which also considers how the corridors will be delivered. Q-S3.2 3 Given the clear deficiency in the supply of brownfield land identified above in response to Question S3.1, Caddick Land firmly believes Option S3.c should be followed. This is not to say that Caddick Land does not support the redevelopment of brownfield land, but the lack of available supply evidenced through the Urban Growth Study is clearly acute, with the Study concluding that ‘… it is unlikely to be possible to meet current development needs without significant greenfield development.’ It would therefore be inappropriate to ‘prioritise’ brownfield land ahead of developing other sustainable greenfield sites. This would result in an artificially constrained supply of housing, particularly at the start of the Plan Period, restricting the ability of both Councils to be able to demonstrate a five -year housing land supply, as required by National Policy. 3.14 Furthermore, it would be inappropriate to carte blanche develop brownfield sites irrespective of their location. This could potentially result in isolated development which is not sustainable and would conflict with other Plan priorities. 3.15 Instead, brownfield and greenfield land should be brought forward together as part of a wider comprehensive growth strategy. Q-S5.2 Caddick Land recognises the benefits of delivering new settlements as part of an overall growth strategy. However, Caddick Land also reiterates the importance of smaller, proportional growth at existing settlements, including both main towns and villages , to allow for coherent and balanced development to occur throughout the Districts. This growth would support the ongoing vitality and viability of existing services and facilities, whilst also allowing for the proportionate expansion of existing neighbour hoods where infrastructure is already in place. A dispersed approach to growth will also allow for the delivery of homes much sooner within the Plan Period, with new settlements delivering in the middle and later stages, up to 2050. Issue S6: A Review of Green Belt Boundaries 3.21 Although there is not a specified question in relation to reviewing the Green Belt boundaries across South Warwickshire, Caddick Land wishes to comment upon this principle. 3.22 Issue S6 outlines the findings of the previous consultation, noting that 54% of respondents supported the exploration of growth opportunities in the Green Belt, compared to only 31% against. Whilst the Consultation Document sets out that the Local Plan pro vides an opportunity to consider whether the existing Green Belt boundaries should be altered to allow for development, there is a lack of evidence at this stage to inform this and therefore comment on (such as a Green Belt review). The Consultation Document accordingly acknowledges that a Green Belt study is required. 3.23 Nonetheless, Aspect has undertaken a site-specific Green Belt review in respect of Land at Warwick Road, Leek Wootton, which concludes that, overall, the Site makes a minor contribution to the purposes of the Green Belt. This is expanded upon in Section 11 of this Representation. 3.24 Any future Green Belt Study should underpin and inform the options proposed as part of this consultation, rather than be led by pre-determined growth options. Based on the evidence that has already been prepared (Urban Growth Study) it is clear that the development requirements with South Warwickshire are such that Green Belt release will be required. 3.25 As a result, Caddick Land strongly supports the requirement for a Green Belt Review, which should be undertaken alongside a review of the submitted Call For Sites to understand and explore potential possibilities available within the Green Belt, to accommodate much needed housing supply and achieve sustainable development, as per the Vision of the Local Plan. Q-S8.1 Q-S8.2 Notwithstanding that Leek Wootton should be apart of the Growth Strategy, Caddick Land does not support a threshold approach as this would serve to restrict windfall growth which may otherwise be sustainable. In this regard, it is submitted that each development should be considered on its own merits, based on the size of the site, the context of the area it sits within and the site’s proposal, such as density, layout,design and potential to support or provide new community facilities. Q-S9 Caddick Land does not support either of these approaches. The purpose of the Part 1 Plan is stated as being to set out the overall strategy for the pattern and scale of growth, which will include allocating sites for development. Some of these sites will be adjacent to existing settlements and it would accordingly be prudent to amend exis ting settlement boundaries to accommodate these allocations (otherwise they would be considered to be ‘open countryside’ in planning terms). 3.34 Any further allocations made through Part 2 Plans would then provide a similar opportunity to make further modifications to settlement boundaries as necessary at that stage. 3.35 Whilst this approach may be different between the two authorities when preparing their Part 2 Plans, it would have a negligible impact. As the supporting narrative to Option S9b suggests, non-strategic land allocations will likely not be made until Part 2 plans come forward. In such cases, it becomes difficult to make appropriate revisions to boundaries in advance of these nonstrategic allocations. Q-S10 Caddick Land wishes to reiterate that a balanced approach should be achieved when looking at the development distribution strategy for South Warwickshire. It is apparent that not all of South Warwickshire’s housing need (in addition to unmet needs of neighbouring authorities) can be met within existing urban areas. There is, therefore, a requirement to develop greenfield sites and review Green Belt boundaries. Nonetheless, in terms of the distribution of this growth, not one individual factor as set out within the Options should be undertaken as an isolated approach. A joined up approach, taking into account infrastructure including public transport access and availability, employment locations, facilities and census information should be considered. Overal l, a wider balanced approach should be considered to ensure a variety of development comes forward, such as infilling and extensions to villages, expansions to urban areas and new settlements can be achieved.

The Study sets out that its purpose is to provide evidence that helps to reduce the need for development outside of South Warwickshire’s 23 existing urban areas as far as justifiably possible. Section 4.6 of the Study identifies that there is a total basel ine housing supply for the 2025-2050 Plan Period of 19,950 dwellings, of which 6,145 would be located within existing urban areas. Caddick Land queries the robustness of this figure, as it is partially derived from development occurring on existing public car parks, which is not considered to be realistic. 3.11 Notwithstanding, the Study then goes on to compare this supply against a housing need for South Warwickshire of 30,750 dwellings across the Plan Period. This figure is incorrect. The Consultation Document and HEDNA seeks to a establish a ‘trend-based’ alternative to the Standard Method, which results in an annual housing need of 868 dwellings per annum (Stratford) and 811 dwellings per annum (Warwick), totalling 1,679 dwellings per annum. Multiplied across a 25-year Plan Period, this need is in fact 41,975 dwellings. Importantly this figure is also exclusive of meeting any unmet need arising from neighbouring authorities, such as Coventry or Birmingham. The identified supply, inclusive of sites within existing urban areas, is therefore less than half of the overall housing need required during the Plan Period. This clearly therefore indicates a need to look to green field sites for development.

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Yes

Q-S4.1 Growth at existing settlements is crucial to ensure their long-term sustainability, vitality and viability of local services such as shops, public houses and sports clubs. This includes settlements of all sizes, whilst also considering accessibility to other nearby service centres, for higher order services and employment opportunities. Q-S4.2 The Settlement Analysis has been undertaken on the basis of a 20-minute neighbourhood principle, using the existing settlements identified as part of the May 2021 consultation. In addition, the Analysis further states that a small number of additional settlements have been further identified and assessed. As a result, it is unclear as to why a review of all settlements has not occurred, or how the settlements that have been analysed were identified as appropriate to add to the analysis. No evidence or justification to demonstrate their position as a settlement is presented. 3.18 In addition, Warwick’s adopted Local Plan sets out a number of Growth Villages 2 , including Leek Wootton. However, the Settlement Analysis that has occurred includes a number of those identified Growth Villages within the Local Plan, including Barford, Bishop’s Tachbrook, Hampton Magna, Hatton Park, Kingswood and Radford Semele, but hasn’t included Leek Wootton. Therefore, it is unclear how the Councils have deciphered this list of smaller settlements within the Settlement Analysis and is not consistent with the approach of the existing Local Plan. 3.19 Furthermore, the analysis states that this was not run alongside the Call For Sites Submissions, therefore Caddick Land requests that a further review is undertaken to assess alternative settlements, alongside the Call For Sites Submissions to ensure it is fully reflective of the wider position. The Analysis does also set out that there is potential for additional settlements to be assessed using the methodology set out in this document, if the spatial strategy to necessitate it. From Caddick Land’s perspective, this needs to occur to ensure the spatial strategy is reflective of South Warwickshire as an entity, and to achieve sustainable development across the whole area.