Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire
I am specifically opposed to development if land in greenbelt areas in/around Weston Under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the North Leamington Greenbelt, including the destroying of much important established habitats. The climate emergency is not a suitable justification to develop on greenbelt land. Developing on greenbelt is truly harmful. There is no option to comment on issues S6 within the plan (review of greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issues should not have been included within the consultation without the option to comment. The number of respondents to the first consultation was incredibly small and cannot be considered representative of the population in the area. It is possible, due to the significantly small number, that these respondents were from developers or others who would directly benefit from such development. This tiny number of responses to the first consultation cannot be used to justify greenbelt development or review. The respondent if forced to answer Q-S5.2, S5.3 & S5.4, with no option to comment. This is unfair and promotes bias as many of the other questions allow comments/further explanation. Not all answers are yes/no and mutually exclusive!
More generally, Southam was identified in the Sustainability Appraisal to the adopted Core Strategy as the most appropriate location for additional strategic growth amongst the Main Rural Centres based on the availability of suitable sites, lack of overriding infrastructure constraints, and the opportunity to support the existing facilities provided in the town. To deny any further growth of Southam in the SWLP to 2050, would not be consistent with the adopted Core Strategy or provisions of the NPPF. HLM have set out a Vision for its site which shows how development could help achieve the five overarching principles of the Plan. This includes a commitment to designing the development to drive down emissions and be more climate responsive. This Vision can sit within and inform a wider Vision for the area, and HLM would be happy to meet to discuss this further with the Councils.
I have not been given the opportunity to comment on whether the greenbelt boundaries should be reviewed. This survey states the results of a survey on this - but does not state where / when these results come from. This is the most important factor that these assessments consider, as a) most of the proposed major development options are within greenbelt, b) building on greenbelt contradicts national planning guidelines, c) the implications of building on greenbelt contradict the objectives stated for the development strategy... That I have been given an opportunity to express on all other issues, but not on greenbelt boundaries appears somewhat strange and I am concerned about the transparency of this process.,
Long Marston Airfield / Meon Vale is identified as a potential new settlement. There is already outline planning permission for the development of a significant amount of housing in this area contingent on highway upgrades to mitigate the impact of this development to the traffic congestion in Stratford-upon-Avon. Thus far, no infrastructure suitable to mitigate increased congestion has been consented, let alone delivered. Any development of this area as a new settlement needs to address its impact concerning congestion in Stratford-upon-Avon with suitable mitigation before any proposed development can take place. The current Green Belt boundaries are impacting on the development of Stratford-upon-Avon. As Green Belt is not located to the west, south and east of the town, recent housing developments have been primarily focused in these area, save for development in the north which now meets with the current Green Belt boundary. Developments in the south and east in particular are having an impact on congestion leading to the town centre from these area, which are served by only two existing road crossings of the Rive Avon. The Town Council supports the proposed review of the Greenbelt boundary if changes can result in sustainable locations for development which do not impact on the five purposes of the Green Belt and also do not add further to traffic congestion issues in the town.
Consideration should be given to the options for further in-fill and brown-field locations for new settlements in and around Leamington Spa before reviewing the current Green Belt boundaries in South Warwickshire. The Green Belt adjacent to our urban centres provides an important function of allowing free access via rights of way to healthy exercise in the form of walking to people of all ages and means. Access to nature has been shown to have many physical and mental health benefits. Therefore careful consideration should be given to alternative options, other than those which, by shifting the current boundaries, could result in the reduction of the Green Belt space near the urban centres of South Warwickshire.
HLM strongly agree with the proposal to review Green Belt boundaries, in order to ensure that the most sustainable growth strategy in South Warwickshire can be achieved. To avoid Green Belt release in the SWLP would limit the potential for growth of a number of South Warwickshire’s more sustainable settlements, including Kenilworth. The SWLP should be supported by an up-to-date Green Belt Study which assesses individual land parcels. In association with a development strategy which supports growth in the most sustainable locations, including on the edge of settlements such as Kenilworth, the Plan should remove land which serves the five purposes of the Green Belt the least.
The original reasons for Green Belts have not changed. They help protect the environment around towns and villages, giving space for people to appreciate the countryside around them, a vital part of everyone's wellbeing, plus allowing the wildlife room to move about. Thus it seems essential to me that Green Belts are maintained. Sue Hallett Nick Wright
More generally, HLM wish to make the point that the South Warwickshire Local Plan clearly must have regard to Coventry City and its proposals for the City. This is not just in terms of housing and jobs, but also transport, services, green infrastructure, etc. Having regard to the City’s ambitions for its City Centre, homes, jobs, and infrastructure, the South Warwickshire Local Plan must play its part and therefore South Coventry must inevitably be a focus for growth within the Plan period to 2050 to support the regeneration and transformation of the City to a modern 21st Century City with an expanded World-Class University, Very Light Rail, City fibre, high quality residential areas, and an innovative economy. Both Warwick and Coventry Councils shared a Vision for land south of Coventry in its adopted Local Plan (Appendix B). That Vision should be refreshed and updated to reflect what has happened since 2017, and to look forward to how this area might be in 2050 with sustainable and active travel infrastructure at its core, with attractive residential communities nestled within green and blue infrastructure. HLM have set out a Vision for its site which shows how development could help achieve the five overarching principles of the Plan. This includes a commitment to designing the development to drive down emissions and be more climate responsive. This Vision can sit within and inform a wider Vision for the area, and HLM would be happy to meet to discuss this further with the Councils and Transport Authorities.
Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Yes, Marriott Estates agree that a threshold approach would be appropriate for any settlement not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the availability of suitable land, proximity to nearby towns, or scale of local employment opportunities. Therefore, the threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.
Long Marston appears to be the current 'winner' in attracting large developments so should be highly considered to be developed into a 'small' town independent of Stratford including all the schools, businesses and shops etc necessary to support such a development - including travel, so far there has not been any successful attempt in providing a transport system resulting in a major issue in Stratford itself.
Why is there no 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.
The South Warwickshire Local Plan Process should fully examine all other options, including new settlement options outside the Green Belt, before starting a study to review Green Belt boundaries in South Warwickshire. An area should maintain its Green Belt status if it meets any one of the 5 purposes of Green Belt, as defined in the National Planning Policy Framework.
The Green Belt is important to prevent urban sprawl
Settlement boundaries are defined with local support in Neighbourhood Plans and these should be respected. New settlements should be on existing transport routes, the rail corridor an example. Minimal extensions to existing settlements, however developing residential opportunities over town centre businesses and town centre brown field sites. Green development in town centres, trees, green walls, planters
Development on north leamington green belt towards Old Milverton and Backdown would result in extra traffic across leamington town centre, development should continue to happen in South Leamington where people work.
Green belt north of Leamington Spa is high quality agricultural land which should be retained for food security It helps maintain distinct boundaries /avoid sprawl between Leamington and Kenilworth Its paths offer recreational access to the public. Green belt retention also encourages brownfield sites and urban regeneration. Green belt north of Leamington meets all five purposes of green belt. Development of the green belt north of Leamington is inconsistent with Govt. policy. The statistic used is misleading, it omits to say that 45% of respondents to its survey were landowners, developers and businesses when it states that 54% are in support of exploring green belt opportunities.
The South Warwickshire Local Plan Process should fully examine all other options AND publish their findings before giving consideration to developments of any kind that change the boundaries of the existing Green Belt in South Warwickshire. To do otherwise would fall short of due diligence, given that the loss of Green Belt is irreversible and will impact future generations long after planning teams and current Warwickshire residents have any interest in the matter. An area should maintain its Green Belt status if it meets any one of the 5 purposes of Green Belt, as defined in the National Planning Policy Framework.
Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Bloor Homes agree that a threshold approach would be appropriate for any settlement listed within Option 5 not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the size and availability of suitable land identified. The threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.
I am concerned at the lack of consultation about the proposed local plan in Claverdon. Someone in Norton Lindsey (where there has been real local consultation) showed me a plan of possible sites for development put forward by Claverdon landowners. When the issue was raised at the last Parish Council meeting, the response was that this was covered by the Claverdon Neighbourhood Plan 2021-31 so that a further response was not needed. No one I have spoken to in Claverdon appears to have been aware that these sites, particularly the one to between Church Road and Saddlebow Lane, could be earmarked for housing development in the SWLP although this would double the size of the village and dramatically impact on an important landscape (identified in the Neighborhood Plan) as well as the feel of the village. New housing development on this scale would also put significant additional strain on the local infrastructure, particularly the water supply, the road infrastructure and the school.
More generally, south of Warwick and Leamington was identified in the adopted Warwick Local Plan (2017) as one of the most appropriate locations for strategic growth based on the availability of suitable sites to deliver sustainable urban extensions, lack of overriding constraints, being outside of the Green Belt and the opportunity to support the existing facilities within the towns. Further growth in this area would be consistent with the achievement of sustainable development as set out in national policy. HLM have set out an Emerging Vision for its site which shows how development could help achieve the five overarching principles of the Plan. This includes a commitment to designing the development to drive down emissions, and provide new and sustainable nearby services and facilities. This Vision sees the provision of a substantial extension of Tachbrook Country Park to provide a permanent buffer between Bishop’s Tachbrook village and the urban area. HLM would be happy to meet to discuss this further with the Councils.
The proposed locations of both employment and housing is highly concentrated in the SE of Warwickshire is a concern for what is a very rural area and to the detriment of the Country park, by both local residents and Burton Dassett PC.
MacMic Group strongly agree with the proposal to review Green Belt boundaries, in order to ensure that the most sustainable growth strategy in South Warwickshire can be achieved. To avoid Green Belt release in the SWLP would limit the potential for growth of a number of South Warwickshire’s more sustainable settlements, including Kingswood. The SWLP should be supported by an up-to-date Green Belt Study which assesses individual land parcels and, in association with a development strategy which supports growth in the most sustainable locations including on the edge of sustainable settlements such as Kingswood, recommends removal of land currently within the Green Belt which least serves the five purposes of the Green Belt, and can define a defensible boundary.
Land at Station Lane, Kingswood, as identified in the attached Site Location Plan, is being promoted by MacMic Group to the SWLP. The site was submitted to the Call for Sites exercise in June 2021 and has subsequently been identified as Site 169 on the Interactive Map. Kingswood is identified as a Growth Village in the adopted Warwick Local Plan. Kingswood has a range of local facilities, including a Primary School, surgery, public house, convenience store, post office, garage, community and sporting facilities. Indeed Kingswood was joint third highest in the Village Settlement Hierarchy Report with a score of 53, and had the highest total score of 64 in the subsequent revised report (V18PM). Kingswood also benefits from Lapworth Railway Station with direct connections to Birmingham, Leamington, London, Solihull, Stratford & Warwick, along with bus provision. Development in Kingswood will assist with sustaining the important facility, which had 84,716 passengers in 2019-20 . Kingswood is also accessible by a good highway network and is located within easy reach of the M42 and M40. Kingswood lies 2 miles (3km) south of Dorridge, 6 miles (10km) south of Solihull and 10 miles (16km) to the north west of Warwick. It is centrally located to other larger settlements such as Birmingham, Coventry, Redditch and Leamington Spa, which offer opportunities for employment, travel and education. Kingswood had an indicative apportionment of 95 dwellings during the previous Local Plan process but only 48 dwellings are allocated in the Local Plan, reflecting the availability of land deemed suitable and available at the time. Therefore, there has been an under provision in the village in the adopted Local Plan, which is likely increasing unmet local needs for housing including affordable housing. Kingswood has a strong functional relationship with the Greater Birmingham Housing Market Area, and growth here would be best placed to contribute towards unmet needs. Whilst Land at Station Lane, Kingswood is currently within the Green Belt, it is in a sustainable location and there are no options for further growth within Kingswood without amendments to the Green Belt boundaries. The NPPF is clear that where Green Belt release is necessary, first consideration should be given to locations that are well-served by public transport . The sustainable effects of attempting to allocate all development outside of the Green Belt, the lack of availability of non-Green Belt land, and the substantial housing need across the Plan area are the initial steps necessary to demonstrate exceptional circumstances in this case. A new permanent Green Belt boundary could be established along the edge of the development. The Site sits within parcel KG2 of the Joint Green Belt Study and performed relatively low to elsewhere, scoring 10/20. In particular the study notes that KG2 has strong boundaries: “The Grand Union Canal represents the eastern border of the parcel. The canal sits close to the existing urban edge of the village and therefore represents a significant boundary preventing encroachment of the wider countryside to the east of the parcel.” Submitted with these representations is a Landscape and Green Belt Study specifically for the Site, which confirms that it makes a limited contribution to the purposes of the Green Belt, and its removal would not undermine the fundamental aims of Green Belt in the wider area. A Concept Masterplan for the Site has been prepared; this details how Land at Station Lane, Kingswood responds to the opportunities and constraints and could deliver circa 125 dwellings, incorporating significant green infrastructure to retain the Site’s landscape character and historic environment setting. This is supported by a Vision Document which provides further detail on the context of the Site and how the emerging proposals respond to this, including the economic, social and environmental benefits to the local community. A suite of technical evidence base work has been prepared in support of the emerging proposals at Station Lane, Kingswood. This includes a Highways Technical Note which concludes that access to the Site can be achieved from Station Lane and that there is scope for the provision of a new footway link to the existing footway network to the south, finding that development can be brought forward without resulting in a significant impact on highway safety or the operation of the surrounding highway network. A Flood Risk and Drainage Scoping Study identifies areas at risk of flooding and realistic on site drainage requirements. The Landscape and Green Belt report considers how development of the Site can be developed whilst respecting the wider Arden landscape character, and will be limited in Green Belt impacts. A Preliminary Ecological Appraisal has assessed the Site’s habitat value and informed the Initial Concept masterplan, in order to ensure biodiversity is protected and enhanced. A Tree Survey has also been commissioned which demonstrates how the majority of trees can be retained in the creation of an access, with replacement trees able to be planted where there is a loss. Overall, there are no technical impediments or environmental characteristics that could not be addressed through sensitive masterplanning, to deliver a high-quality proposal in this location.
The Heritage and Settlement Sensitivity Assessment details the range of historic environment assets in Kingswood and the ability for additional development to be brought forward in the settlement taking into account potential impacts. The Assessment finds that land to east of Kingswood has potential for development, with the historic environment limited to two Listed Buildings (both Grade II) and Conservation Area. The Concept Masterplan and Vision Document for Land at Station Lane, Kingswood detail how suitable consideration has been afforded to these historic assets. It is clear that further growth to the south of Kingswood is unlikely to be able to be accommodated without significantly impacting the local historic environment, including the Conservation Area and a series of Listed Buildings. Concerns are also raised with development potential of the west of Kingswood recognising the Listed Buildings (including Grade I Listed Packwood House) and Registered Park and Garden. Land to the north of Kingswood performs well in historic environment terms, however development to the north of Rising Lane would not be proximal to any of Kingswood’s local services and facilities and would extend the built form of the settlement contrary to the existing pattern of the settlement. This is also likely to be challenging for a Green Belt release perspective, with no strong identifiable boundaries. As such, whilst development of land north of Kingswood may be most preferable from a historic environment perspective, other factors suggest this location is not suitable for further growth of the settlement.
- Q-S2: We support option S2B. An ‘in principle’ policy support for intensification is appropriate subject to design guidance. This would support making best use of existing urban areas. - Q-S3.2: We support option S3.2a. An ‘in principle’ support for brownfield development where it corresponds with the growth strategy. This would support making best use of existing urban areas and previously developed land. - Q-S4.1: Yes growth of existing settlements should be the main option within the overall growth strategy. This ensures making best use of existing infrastructure and sustainable patterns of development. Please see full response to this at Q-S7.2. - Q-S5.2: We are not against the principle of new settlements but the history of these shows that they require significant new infrastructure and take a long time to be delivered. It is critical that if such is part of the strategy they must be proven to be viable, deliverable, accessible and sustainable, and only one part of the overall strategy. We would only support a new settlement(s) to be part of the preferred option if combined with the growth of existing settlements. Existing settlements are supported by existing infrastructure and are inherently more sustainable and can be delivered quicker than new settlements thus securing housing supply in the earlier stages of the Local Plan. - Q-S8.2: Although in principle a threshold approach could provide useful guidance for a smaller settlements growth, a standardized approach is difficult as settlement sizes vary enormously. A standard limit of 10 dwellings as suggested is certainly too small as whilst it may be appropriate in a very small settlement, it would be too low for many settlements. A limit of 10 units also results in no affordable housing being provided. If a standard threshold is considered necessary it should be expressed as a % of the houses in the existing settlement. - Q-S9: We support Option S9b. It is clearly essential that the Part 1 Plan should include a fresh review of all settlement boundaries. This issue of settlement boundaries raises the problem of pursuing a 2 stage Local Plan which we do not support. See our full response to Chapter 12: Plan Context.
I oppose the encroachment on green belt and the underlying assumption that growth is good.
Question feasibility of developments proposed for 'light industrial use': a) opposite Dial House Farm near Ashow. This is land that forms a clear boundary from the A46 and Kenilworth, is agricultural green belt land and protects the ancient ‘bluebell’ woodland (Thickthorn Woods)... and, b) grade l* listed Stoneleigh Abbey historic park and garden land off B4115 towards Rocky Lane and Ashow village. The proposed site would be highly inappropriate to be considered for any form of development based on the historical context and visual impact/ importance - this land is parkland and protected status, not open to commercial purposes. The proposed ‘red’ coloured area of land within the conservation area of Ashow Village is a parcel of land previously strongly opposed for development by c50 plus local residents within Ashow village and the local community, therefore I would wish to highlight that this is not a suitable development area. Please find attached the two withdrawn Planning applications that were submitted back in 2017 that were strongly objected to by the local community. W/17/0778 | Proposed erection of 4no. two storey, semi-detached dwellings. | Land between Rock Cottage and Field House, Grove Farm Road, Ashow, Kenilworth, CV8 2LE W/17/0785 | Proposed erection of 2no dwellings | Land adjacent Rock Cottage, Grove Farm Road, Ashow, Kenilworth, CV8 2LE
This strategy is politically driven and in no way reflects the locals in rural areas.
It is very clear that there are considerable differences in the approach between the 2 Districts and that is will take a long time to harmonise the differences into a single strategy. Respondents are asked to choose between the 2 approaches with the caveat that choice will result in delays if issues are pushed to Part 2. It isn't really possible for a lay person faced with a 1000 page document to ensure a coherent choice all the way through. The consultation puts forward the need for a Green Belt review on the basis that much of Warwick DC is green belt and cannot accommodate unmet need for housing from other areas. Whilst not necessarily against a review it does seem odd that this is the reason given, There are no indications of the criteria, mechanisms or timetable that will be used; Lapworth Parish Council consider that it is essential to articulate clearly and set out for public agreement South Warwickshire's unique characteristics before any Green Belt review takes place to ensure that the proper function of the Green Belt is maintained. The plan, comprehensive as it, does not address the issue of improving existing settlements in terms of infrastructure. Lapworth Parish Council would like to be consulted with and involved with any proposals arising from the Consultation in relation to this chapter,
- Issue S2: Intensification - We support option S2A. This would support higher density development in the existing urban areas, which are more suited to this type of development. - Issue S3: Using Brownfield Land for development - QS3.2 -We support option S3.2a. An ‘in principle’ support for brownfield development only where it corresponds with the growth strategy and would assist to deliver the vision and strategic objectives. - Issue S4: Growth of existing settlements - The growth of existing settlements should be a central pillar within the overall growth strategy. This ensures making best use of existing infrastructure, delivering more sustainable patterns of development that seek to protect more of and the character of the open countryside. Please see full response to this at Q-S7.2. - Issue S6: A review of Green Belt boundaries - We note that there is no Question on this at this stage but would repeat our response on this matter made at the Local Plan Scoping Stage that a Green Belt review is critical to the core evidence base which will be required to underpin the South Warwickshire Local Plan. We also note that 54% of respondents at the scoping stage supported the exploration of growth opportunities in the Green Belt. - Issue S8: Small scale development outside of the chosen spatial growth option - We do not agree with a threshold approach for settlements falling outside the chosen growth strategy, as there is no planning justification for this, each application should be determined on its merits. Furthermore, a standardized approach is difficult as settlement sizes vary enormously. For example, a standard limit of 10 dwellings may be appropriate in a very small settlement, but would be far too low for most settlements. A limit of 10 units also results in no affordable housing being provided. If the Council do decide to include a threshold, we would suggest that this should be linked to and expressed as a percentage of the size of the existing settlement rather than a standard number of dwellings. - Issue S9: Settlement Boundaries and infill development - We support Option S9b. It is clearly essential that the Part 1 Plan should include a fresh review of all settlement boundaries. This issue of settlement boundaries raises the problem of pursuing a 2 stage Local Plan which we do not support. See our full response to Chapter 12: Plan Context.