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

1. MISUSE 0F GREEN BELT LAND WHICH WOULD CREATE BIGGER PROBLEMS The proposed development in Henley-in-Arden is completely out of proportion to its present day capacity. In proposing to use the designated green belt, it would create many problems to a small town already suffering from a serious decline in infrastructure for its inhabitants especially the young families with children which could only increase the following problems listed below :- 1. A lack of good quality provisions being essential groceries and vegetables 2. Medical care, both Henley Medical and the Chemist are struggling to cope with existing demand. 3. Education, Henley High School is already over-subscribed and would not be able to cope with ensuing extra demand. 4. Parking, which at present is totally inadequate resulting in many inhabitants seeking alternative venues to avoid the problems. 5. Henley lacks investment from business startups because of lack of infrastructure as stated. Henley lies between two much larger urban developments in a section of Green Belt land which serves to prevent urban sprawl extending such that the developed envelopes extend to such an extent that they join. To the south, there is extensive white space on the outskirts of Stratford upon Avon, for example, which is ideally suited to development that meets the needs of a modern economy that is responsive to the environmental demands and the new working patterns that have emerged as imperatives in recent years. Development of brownfield sites around existing urban envelopes is consistent with modern planning policy that co-locates living, working and leisure spaces, and preserves the integrity of the nearby Green Belt and all of its benefits. Stratford District Council itself highlights the evidence that supports this argument: “Unemployment across the District is low, with 0.3% of workers claiming jobseekers’ allowance in May 2016. This is lower than the UK average (1.8%) and West Midlands average (2.2%). There is an imbalance between the number of jobs in the District and its working population. An increasing number of residents commute to higher paid employment outside the District, while lower paid jobs are often filled by people coming into the District from adjoining areas. These commuting patterns impose significant pressures on the road network. Employers in and around Stratford-upon-Avon can struggle to recruit staff into lower paid and part time roles and cite the absence of affordable commuting options, particularly outside of peak travel times, as a barrier to filling vacancies.” 2. ERODES THE COMMITMENT TO THE PRESERVATION OF THE GREEN BELT The West Midlands Green Belt wraps around Birmingham, the Black Country and Coventry and extends to a ring of towns beyond the conurbation. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch (apart from small areas of land to the west of Mappleborough Green), Bromsgrove, Solihull and Warwick. The settlements of Alcester, Henley and Studley are excluded from the Green Belt. Commitments from Stratford and Warwick in the existing planning frameworks reiterate a commitment to the integrity of the Green Belt and the prevailing government guidance and policy in respect of the Green Belt. It is critical that the Green Belt around Henley is preserved for its environmental benefits and the health and social benefits that it brings to residents. The proposed development is inconsistent with commitments made in the existing planning policies. 3. SIGNIFCANT INFRASTURCTURE LIMITATIONS AND CONSTRAINTS Traffic Limitations: Existing Plans to Match funding has been secured to calm traffic on the High Street in an initiative to impose during the first six months of 2023 a 20-mph speed limit on the High Street and commuter ‘rat run’ cul de sac roads that lead off the main artery. It is counterintuitive to simultaneously restrict the flow of traffic through the town – a demonstrated need in response to recent traffic safety issue – and at the same time expand the volume of traffic resulting from increased housing development around the town. Poor Bus Links: No Bus service between Stratford upon Avon and Birmingham The bus and train infrastructure is insufficient to sustain the existing population, before considering an additional 2,000 residents which might result from the proposed development. The X20 bus service runs 12 buses a day on a weekday and covers the North – South route between Stratford and Solihull. Bus passengers requiring to travel East – West to Redditch and Warwick are required to travel to the end of the north or south routes and then change to another service. Stratford District Council agree – the 2018 SDC Transport Strategy reports that “A key barrier to bus use is journey length and issues of punctuality and service reliability which are exacerbated in Stratford-upon-Avon by congestion”, which is central to the operation of any bus routing to service Henley-in-Arden. Further, SDC reports that “bus passenger facilities … are currently insufficient for the volume of passengers….” Impact of Closure of the M40 and other Congestion: With the current level of housing, any closure of the M40 south of the M42 junction leads to the diversion of traffic off the motorway and through the town, predominantly using the north-south axis along the High Street. Statistics show that the M40 is the subject of a temporary closure between 3 and 4 times a year. Roadworks anywhere in the town – typically driven by servicing the antiquated drainage system and other infrastructure – currently creates significant delays in the town. Additional development will have an adverse impact on the existing street scape within Henley. Inability to Expand or Widen Existing Roads to Accommodate Traffic: Henley-in–Arden is a medieval market town with a strong architectural heritage reflected in the North – South road axis and the listed buildings which line the A3400 and High Street. The listed buildings which exist along the main roads in the town preclude any expansion or widening of the road to accommodate increased volumes of traffic arising from increased development and volume of housing. Road Safety: An increase in development in or around Henley-in-Arden will lead to an increase in traffic of all modes to service population movement around a market town based around two intersecting roads. A brief review of the traffic accident statistics for Henley in Arden for the last five years shows twenty-five incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all which centre on the High Street and the crossroads at the South of the town. An increase in population of the scale proposed by the draft Plan would inevitably lead to an increase in road traffic casualties. Car Parking: Car parking is an acknowledged problem in Henley-in-Arden, where the existing historic housing prevents the development of extensive car parking and on-street parking on the High Street predominates and cars have been forced into small off-street parking facilities – such as that behind the Co-op store. The proposed plan makes no accommodation for the resultant car traffic that would be generated by extensive development around the town. Air Quality and the Environment: Development of the scale proposed will have a disproportionate and adverse impact on air quality and other factors driven by additional traffic from the aggressive development proposed by the town. Propensity to Flooding: Henley-in-Arden is famously susceptible to flooding, and certainly more so than other sites and locations proposed in the plan. The SFRA highlights that Henley is one of the most sensitive areas in the Stratford District to the fluvial impacts of climate change. The town rests at the base of a hilly catchment area providing an obvious outlet for when the river Alne floods, as it did most notably in memory in 2007. Additional development would increase the impact of that flooding and place greater demands on the surrounding environment in the event of flooding. No Potential to Future Proof the Infrastructure: There is no obvious solution to the problem of future-proofing any development proposed in Henley-in-Arden. Ageing water and sewerage infrastructure means that there is little chance of expansion or the development of the infrastructure of the future, particularly electric charging points for cars and the support of renewables. 4. LOCAL SERVICES ARE INADEQUATE TO SUPPORT PLANNED EXPANSION: An increase in the housing stock in Henley-in-Arden such as that proposed in the draft Plan would require additional infrastructure investment, most obviously in schools and medical facilities. Henley in Arden School is part of the Arden Multi-Academy Trust. It has a capacity of 700 pupils and yet already has 710 pupils enrolled. Expansion would inevitably be necessary to sustain development of the extent proposed and local government would need to provide funds. The existing medical practice moved from the High Street to the existing site in 1990, and access is via a footpath from the High Street or via car through a housing estate to a council run car park. Again, the site of the existing facility and the lack of potential for expansion into surrounding space means that expansion in Henley-in-Arden would require a new medical facility in a new location. Any expansion of either of these facilities or the commission of new sites would inevitably lead to an increase in the risk of road, pedestrian and traffic incidents as a direct result of the crossroads and road configuration which dominates the town. 5. ABSENCE OF A FOCUS ON LOCALISM: The outline proposals make no reference to even the sense of the principles of localism in the Henley-in-Arden community and run contrary to local sentiment. Those responsible for the development of the plan must provide opportunities for communities to influence decision-making. support placemaking and. deliver services that reflect local requirements. The scale of the development proposed is completely inconsistent with the scale of the existing town and the development of the population to date. Between 1975 and 2015, the population of Henley grew by 14.3%, and grew even more strongly in later years where between 2000 and 2015, it grew by 10.2%. Using data and projections from one. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Centre for International Earth Science Information Network), the population in 2022, stood at 2,571. Assuming an average of 3.5 heads occupying a lower estimate of 500 additional houses in Henley-in-Arden as proposed in the Plan, the population of the town would grow by 68%, which is completely disproportionate development. The plan ignores Stratford Council’s own observations about the importance of Henley’s heritage and the impact of further development upon it. The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan of September 2022 observes that “The setting of some of (the) assets, particularly the castle and church, are still currently experienced within the historic open agricultural landscape. It is therefore recommended that development of the land beyond the north-eastern edge of the settlement should be avoided.” There are also similar observations about the land to the south-east and south-west of the town which are completely contrary to the scale of the development proposed in the plan. Similarly, there is little consideration of the sites north of the Warwick Road (reference HEN.02 in the Stratford Heritage Assessment) where the RED assessment risk of both harm to surviving Ridge and Furrow and harm to archaeological monuments runs contrary to the proposed sites offered for development to the East of the town. The economy of Stratford upon Avon is delicately dependent on visitors and those in search of rural tourism – the strength of demand is such that the town has its own Heritage Centre for visitors and queues for the locally-made ice cream regularly generate queues that extend up the High Street. Extensive development of the type which is proposed would jeopardise local businesses and a tourism-centred town: Solihull was originally a pleasant town in the Green Belt – literally ‘Urbs in Rure’ – but development without reference to local concerns has let it evolve into something much different. 6. INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable. References: 1. Traffic calming: https://www.stratford-herald.com/news/henley-in-arden-to-get-20mph-speed-limit-along-high-street-9280462/ 2. Bus Frequency: Stagecoach timetable 3. Traffic accidents: https://www.crashmap.co.uk/Search 4. Bus Infrastructure: https://www.stratford.gov.uk/doc/206646/name/Adopted%20Stratford%20Area%20Transport%20Strategy.pdf 5. Impact of Traffic on Environment: https://www.stratford.gov.uk/doc/206646/name/Adopted%20Stratford%20Area%20Transport%20Strategy.pdf 7. SFRA: https://www.stratford.gov.uk/planning-building/water-and-flood-risk.cfm

Green belt development I am opposed to building on green belt land around the two villages. We have already lost much to HS2 and further loss must be avoided. With the loss of green belt the whole area is completely changed from rural to urban and this can never be reversed. The green belt around and between the two villages is agricultural land where arable crops are produced, and some animals are grazed. There has been much talk about food security and we have seen the effects of the Ukraine war in this respect. As a nation we cannot afford to take yet more land out of production to build houses, making us more dependent on food imports with its attendant risks and contribution to global warming. Biodiversity loss I (live) trap moths in my garden, which overlooks the land under consideration. In the last four years I have recorded 58 species, none of them rare, although some are quite local and not very widespread. There have often been quite large numbers of some species. Moths are a good indicator of a healthy environment and they make use of the various habitats to be found on this land. Particularly important are the hedges which, as well as providing many of the food plants needed by moth larvae, and flowers for the adults, also provide hiding places and green corridors for these and many other species of animals. We have a wide range of other insects including many wild bee species (bumblebees and solitary bees), important as pollinators. These all need nesting places and flowers, again often provided by hedges and field margins. The new Environment Act (2021) states as aims that the decline in biodiversity should be halted and the recovery of wild-life should be supported. It is difficult to see how building houses in this area can do that. Infrastructure These development plans, if they go ahead, need to address the need for more medical care (already overstretched), school places and better roads as many of the existing ones are narrow lanes, not designed to carry more traffic which would be generated by building this large number of houses. We have no shops in either of the villages apart from Hilltop Farm shop so many more car journeys would be generated, so adding to pollution. More pollution would be caused during the building process by the movement of lorries in the area and, as we have seen with HS2, this would also lead to still more road closures and restrictions, adding to the misery of many villagers.

Concerning sites offered so far Barford has concerns. The site off Westham Lane, west of Barford Bypass, should be rejected on multiple grounds including difficulty of access off Barford Bypass, intrusion in the landscape, loss of BMV land and separation from local services. Furthermore, we would suggest another Red Line along Barford Bypass prohibiting significant developments west of that route, with perhaps revisiting the older concept of the “Avon Valley Area of Restraint”. Land around Barford House has been offered for residential development and is currently against all local policies, a situation which should persist, unless there is an offering specifically to comply with Policy B3 of Barford NDP, which specifically seeks provision for housing for the aged and infirm.

1.2 Taylor Wimpey is promoting approximately 14 hectares of land east of Hockley Heath, which represents a new sustainable and deliverable residential neighbourhood. 1.3 The site was submitted via the Call for Sites exercise in June 2021 and identified by the following site reference 154. Additionally, Taylor Wimpey submitted representations to the Scoping Paper in June 2021. 1.4 These representations should be read in conjunction with the supporting Vision Document. 1.5 Section 2 of this statement provides a summary of the site and the opportunity that the neighbourhood presents for South Warwickshire 2. The site and the opportunity 2.1 This section describes the opportunity of the site in terms of its geography and its prospects for delivering a new neighbourhood at Hockley Heath. Description of the site 2.2 The site is situated south of Aylesbury Road (B4101) on the eastern edge of Hockley Heath. The site offers an area of approximately 14.4ha of agricultural land comprising of three fields, currently designated as part of the Green Belt. The site is bound by public footpaths, a drainage network, woodlands and shrub planting. 2.3 The site has a gradually falls from a high point located in the north-west corner of the site at approximately 141m (AOD) falling toward the south-eastern corner at 125m (AOD). 2.4 Directly to the north of the site, the former Aylesbury Country House Hotel and grounds (Grade II listed) is being converted and grounds redeveloped to provide 17 residential dwellings. 2.5 The western edge of the site forms the administrative boundary of Solihull Metropolitan Borough Council (SMBC) with the site falling wholly within the administrative control of Warwick District Council (WDC). The opportunity 2.6 The site has the capacity to deliver circa 300 new homes based on a density of 35 dwellings per hectare on an 8.9 hectare developable area. The site will comprise a mix of different types, tenures and sizes – including market and affordable homes. This approach will create a balanced and sustainable neighbourhood that meets the identified needs of the south Warwickshire area. 2.7 The non-developable area will comprise access routes, a hierarchy of streets to facilitate safe pedestrian and cycling movement and be knitted together by a central parkland (1.7ha) and surrounding green infrastructure, woodland and open space (3.97ha) 2.8 The connectivity potential of the site to the centre of Hockley Heath; the wider area of south Warwickshire and Solihull; along with its proximity to the HS2 Interchange Station, presents a real benefit for future residents. Such connectivity will allow future residents to travel sustainably to a variety of employment and recreational opportunities. 2.9 In planning terms, the site is deliverable for new homes subject to its removal from the Green Belt. This is based on the following: Available 2.10 The site is available for residential development based on the following: 3 • There are no legal or ownership impediments to development. • The land is in dual ownership. • The land is subject to an option with an intent to develop. • Taylor Wimpey has an excellent delivery record in South Warwickshire. • The site is not subject to a history of unimplemented permissions. Suitability 2.11 The site is suitable for residential development because of the following factors: • It is not subject to any technical constraints which cannot be avoided or mitigated. • There are no international and/or national environmental designations. • Its neighbouring use is also residential. • The market attractiveness of the geography is high. Achievability 2.12 The site is achievable for residential development because: • New homes can start to be delivered within five years following permission. • It is currently economically viable subject to planning obligations. • Taylor Wimpey has the capacity to complete and sell new homes early in the plan period. 2.13 The full constraints and opportunities are described in the accompanying Vision Document (Appendix 1) and an illustrated development framework is provided to visually express how the new neighbourhood will be a place for living and playing.

3.15 Hockley Heath is not identified or assessed within any refined spatial growth option which is limiting the selection of an appropriate strategy for South Warwickshire. This omission needs to be addressed in new and/or updated evidence on the spatial distribution of growth. 3.16 Nevertheless, Taylor Wimpey deems a blended approach of all five growth options to be an appropriate strategy for distributing new homes across South Warwickshire and on its administrative borders. 3.17 In the context of a blended approach, Table 1 sets out how Hockley Heath as an existing settlement would perform in relation to the objectives of the Sustainability Appraisal: Table 3.1: Hockley Heath settlement score Objective Impact score SA1 Climate Change Minor adverse SA2 Flood Risk Negligible SA3 Biodiversity Minor adverse SA4 Landscape Minor adverse SA5 Cultural Heritage Minor adverse SA6 Environmental Pollution Minor adverse SA7 Natural Resources Major adverse SA8 Waste Minor adverse SA9 Housing Major positive SA10 Health Minor adverse SA11 Accessibility Minor adverse SA12 Education Minor adverse SA13 Economy Minor positive 3.18 The sustainability performance of Hockley Heath is comparable to most of the identified small settlements in the Sustainability Appraisal.

3.19 Option S9b is the most appropriate option for South Warwickshire as there will undoubtably be a need to review and alter some existing settlement boundaries to accommodate the housing requirement up to 2050 on land adjoining existing sustainable settlements, including Hockley Heath. 3.20 Option S9b is consistent with paragraph 73 of the NPPF in that it will allow for the supply of large numbers of new homes to be delivered by significant extensions to existing villages and towns “provided there are well located and designed, and supported by the necessary infrastructure and facilities”. 3.21 Option S9a will preclude the SWLP from being positively prepared and consistent with national policy as existing settlement boundaries were formed on out-of-date evidence on development need and sustainable patterns of growth. This is inconsistent with paragraph 31 of the NPPF.

1.0 INTRODUCTION 1.1 This submission is made on behalf of L&Q Estates, in relation to their interests at land east of Banbury Road, Southam (hereafter referred to as ‘the Site’). L&Q Estates welcome the opportunity to be involved in the preparation of the South Warwickshire Local Plan (SWLP), and it is within this context that they wish to make representations to the Regulation 18 Issues and Options Consultation. 1.2 On behalf of L&Q Estates, we have previously submitted the Site to the SWLP Scoping Consultation (2021) and the Site was submitted in response to the Call for Sites exercise in 2021. 1.3 The Site is shown outlined in red on Drawing Edp2535_d067c (Appendix 1) and is located to the southern edge of Southam. It extends to 11.68 ha (28.86 acres) and has potential to deliver a residential scheme of up to 200 dwellings, in addition to public open space, a community orchard and allotments. 1.4 The site is deliverable, available and suitable to deliver a high-quality residential development that will significantly assist in meeting South Warwickshire’s identified housing need as well as the unmet need from Coventry and from Greater Birmingham and the Black Country.

Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.8 Yes, we consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. 3.9 South Warwickshire has a dispersed settlement pattern (as set out in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy) and is home to a significant number of existing settlements of varying sizes. The explanatory text under Issue S4 sets out that there are nine towns (Alcester, Henley-in-Arden, Kenilworth, Royal Leamington Spa, Shipston-on- Stour, Southam, Stratford-upon-Avon, Warwick and Whitnash), at least 82 villages and hundreds of hamlets. 3.10 Issue S4 sets out that the South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet development needs to 2050. However, in deciding upon the best distribution strategy for new development within South Warwickshire, it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements. 3.11 Southam is categorised as a ‘Main Rural Centre’ in Policy CS.15 of the adopted Stratfordon- Avon Core Strategy. The settlement hierarchy is defined below: 1. Main Town: Stratford-upon-Avon 2. Main Rural Centres (including Southam) 3. New Settlements 4. Local Service Villages 5. Large Rural Brownfield Sites 6. All other settlements 7. Local Needs Schemes 3.12 Therefore, Southam is identified as one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-upon-Avon district. 3.13 Southam town centre contains a range of shops, commercial activities such as banks, local services and facilities and pubs. Other services in the town include primary and secondary schools, a leisure centre, library, medical centres, police station and post office. There are good public transport services to the towns of Leamington Spa and Rugby, as well as community transport services that connect the town with nearby villages. 3.14 There is an established employment area on Kineton Road that provides a range of jobs. This has seen a significant expansion in recent years and comprises a traditional industrial estate. The town has been successful in attracting a number of large companies. 3.15 Paragraph 6.7.6 of the Core Strategy acknowledges that Southam functions as a service centre for much of the eastern part of the District, stating: ‘A large number of rural communities look to the town for their everyday needs. Some of these are quite sizeable, such as Harbury, Long Itchington, Napton and Stockton. Southam College strengthens the town’s role due to its extensive catchment which includes neighbouring parts of Rugby Borough.’ 3.16 Southam is one of the largest rural centres in the District and is a focal point of shops, services and jobs for a sizeable rural catchment. Indeed, paragraph 6.7.9 of the Core Strategy concludes that: ‘it is reasonable for the town to be considered suitable for additional housing and business development.’ 3.17 These paragraphs and conclusions remain broadly valid. It is consistent with national planning policy and basic sustainability principles to ensure that housing is focused in existing settlements, such as Southam, where there are existing services and where there is a need to ensure vitality. 3.18 Land east of Banbury Road, Southam immediately adjoins the built-up area boundary of Southam and existing residential development to the north and west. Southam has been subject to a number of residential planning applications. A residential development of 47 dwellings (LPA Ref. 14/00503/OUT and 16/02091/REM) has recently been constructed, filling in a square parcel of land to the immediate west of Land east of Banbury Road, Southam. Furthermore, an application for 236 residential properties (Ref. 13/00809/FUL) and redevelopment of Southam United Football Club to a community sports hub has extended the settlement boundary further south along the A423 Banbury Road, opposite the Site [land east of Banbury Road, Southam]. 3.19 The promotion site would reinforce the established built form at the southern edge of Southam and would form an enduring definition to the built-up area boundary. Indeed, the site is contained by hedgerows along its southern boundary which act as a green buffer and sensitive transition between the town and surrounding landscape. 3.20 The promotion site would be well connected to the built-up area of Southam and would constitute sustainable development. Indeed, it is considered that the new homes at Land east of Banbury Road will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Southam’s services and facilities. 3.21 Given the pressing need for additional housing within the Stratford-on-Avon District, Southam is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site should be allocated as a residential site within the South Warwickshire Local Plan.

Option S2-C: Intensification 21. Intensification is a way to optimise brownfield land and realise its effectiveness. However, HLM consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 22. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided.

Q-S4.1: Growth of Existing Settlements 28. Yes, growth of existing settlements in South Warwickshire (and on the edge of South Warwickshire) is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure are all generated within the existing settlements. Those needs are best met sustainably adjacent to the settlements, rather than in new settlements.

Q-S7.2: Refined Spatial Growth Options 38. HLM consider a mixture of options will be required to best deliver the growth needs of South Warwickshire for the reasons as set out below. 39. Firstly, the results of the high level testing of the five growth options in the supporting Sustainability Appraisal demonstrates that the options perform differently in different areas, with no one option standing out as the best performing option across all areas. 40. Secondly, it is important to remember that the assessment set out in the SA is provided at a high level, subject to several caveats, and without consideration of mitigation or deliverability. Options which score less favourably in the SA could therefore actually deliver more sustainable growth on closer examination. 41. Finally, given the significant level of growth the SWLP will need to accommodate (see response to Issues H1 and H4 below) this is unlikely to be able to be met sustainably through a single growth strategy. 42. HLM also have the following comments on the Options. 43. HLM query why growth South of Coventry appears to be limited to the Kings Hill SUE for the Rail Corridors (1), Sustainable Travel (2) and Sustainable Travel and Economy (4) Options. The consultation document recognises that infrastructure thresholds for new railway stations are 6,000 homes (Table 3). As Kings Hill is only 4,000 homes, an additional 2,000 homes would be necessary to support the viability of a new station. The HLM site would make a logical extension to Kings Hill SUE, connecting this SUE with a new Coventry South Railway Station as proposed by the Transport Authorities, and delivering around 1,300 additional homes that contributes to its viability and delivery. HLM therefore request these options (1, 2, and 4) are amended to include at least an additional 2,000 homes at South of Coventry. 44. HLM also make the following specific comment in relation to the Sustainable Travel Option (2). Reference is made to bus corridors, but no reference is made to Very Light Rail which Coventry City Council are proposing to develop into Warwick District within the Plan period at Kings Hill SUE and the HLM site (see below). It is noted in Issue T2 that people responded to the previous consultation by commenting that focus should be on encouraging the use of very light rail. The Sustainable Travel Option should have regard to the Very Light Rail proposals, and therefore include growth options along its route (namely the HLM site). 45. HLM also make the following specific comment in relation to the Economy Option (3) and Dispersed Option (5). These options include a significant urban extension south of Westwood Heath and Warwick University. It is acknowledged this is an indicative location for growth, however any major development in this location south of Westwood Heath could not be commenced until the A46 Strategic Link Road has been completed, which goes through the HLM site. Given the proximity of the HLM site to the University and surrounding employment areas, and the planned active and sustainable travel infrastructure for this area, the best solution for the Economy and Dispersed Options would be to spread growth across the area South of Coventry to ensure the best use is made of planned infrastructure and connections to jobs. Q-S10: Other Development Strategy Issues 46. 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. 47. 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. 48. 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.

Option S2-C: Intensification 19. Intensification is a way to optimise brownfield land and realise its effectiveness. However, HLM consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 20. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided.

Q-S7.2: Refined Spatial Growth Options 36. HLM consider a mixture of options will be required to best deliver the growth needs of South Warwickshire for the reasons as set out below. 37. Firstly, the results of the high level testing of the five growth options in the supporting Sustainability Appraisal demonstrates that the options perform differently in different areas, with no one option standing out as the best performing option across all areas. 38. Secondly, it is important to remember that the assessment set out in the SA is provided at a high level, subject to several caveats, and without consideration of mitigation or deliverability. Options which score less favourably in the SA could therefore actually deliver more sustainable growth on closer examination. 39. Finally, given the significant level of growth the SWLP will need to accommodate (see response to Issues H1 and H4 below), this is unlikely to be met sustainably or efficiently through a single growth strategy. 40. HLM also have the following comments on the Options. 41. HLM query why growth at Southam does not appear in the Sustainable Travel (2) Option. As a town with a population of over 8,000, and a sizeable employment area, the town should continue to receive investment in high quality public transport connections to Royal Leamington Spa, Coventry, Rugby, and Daventry. The frequency and quality of services can be improved with investment and increased patronage that strategic growth can deliver. 42. If the aim for the Plan is to deliver a well-connected South Warwickshire, then a town the size of Southam needs to have investment in its public transport connections to 2050. Q-S10: Other Development Strategy Issues 43. 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. 44. 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.

Option S2-B: Intensification 4. The focus of the discussion in the Consultation Paper relates to how intensification can be undertaken to increase housing delivery. However, it needs to be recognised that the same policy can support increase in employment floorspace and jobs. An ‘inprinciple’ policy support for intensification on key employment sites would be supported by Jaguar Land Rover.

Q-S7.2: Refined Spatial Growth Options 6. Jaguar Land Rover have the following comments on the Options. 7. Jaguar Land Rover query why employment growth at Gaydon does not appear in the Sustainable Travel (2) Option. The planned investment in bus corridors connecting Gaydon with nearby towns will result in this location being on a main bus corridor. 8. It is worth remembering that paragraph 73. a) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The Spatial Growth Option chosen within the Plan should therefore take into account the planned bus services at Gaydon. 9. Jaguar Land Rover support employment growth at Gaydon appearing in the Economy (3) Option and Hybrid (4) Option. However, employment growth at Gaydon does not appear within the Dispersed (5) Option diagram, and this anomaly should be addressed in the next iteration of the Plan. 10. Whichever option or combination of options is chosen, Jaguar Land Rover support a strategy that includes employment growth at Gaydon.

Q-S4.1 Growth of Existing Settlements 15. Yes, growth of existing settlements in South Warwickshire is considered to be imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. Further, growth of existing settlements will support the sustainability and vitality of existing services, providing support to existing communities, which in turn has the potential to enhance placemaking and sustainability. 16. Whilst the potential for new settlements in South Warwickshire is recognised, they will not ensure delivery of growth in the early part of the Plan period or sustain and enhance the vitality and sustainability of existing settlements. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure is within the towns and villages; those needs cannot be directly met sustainably in isolated settlements.

Q-5.2 The Potential for New Settlements 24. No, MacMic Group are of the view that new settlements should not form part of the strategy for dealing with South Warwickshire’s development growth needs, due to concerns regarding lead-in terms, infrastructure requirements, viability and market attractiveness. However, the expansion of existing settlements where there are opportunities to capitalise on existing benefits that new settlements are striving for should be considered. This would need to be supported by the allocation of sites which are deliverable in the short-term in sustainable locations, such as adjacent to Kingswood. This will help maintain and enhance the vitality and sustainability of existing settlements and deliver the need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure within the towns and villages where such needs exist. 25. With regard to the potential new settlement C1 south of Kingswood, it is considered that this site is too close to Lapworth Railway Station to warrant growth of 6,000 dwellings to facilitate a new Railway Station. Whilst potential new settlement C1 could come forward and deliver significant infrastructure including a Primary School and Secondary School, MacMic Group consider that a standalone new settlement south of Kingswood would not maximise the significant benefit that the existing Lapworth Railway Station has to offer. 26. As such, MacMic Group consider that, should significant growth in this location be considered appropriate, the focus should be the existing settlement of Kingswood and a significant expansion of the village in order to maximise the offer of Lapworth Railway Station. This would allow the delivery of significant growth to meet the needs of South Warwickshire in a location well related to conurbation with unmet needs supported by the provision of significant new infrastructure, whilst maximising the potential and also sustaining the existing Lapworth Railway Station.

Issue S6 A Review of Green Belt Boundaries 27. 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. 28. 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.

Q-S7.2 Refined Strategic Growth Options 29. The SWLP Issues and Options consultation presents five growth options which are proposed as potential solutions to deal with meeting South Warwickshire’s requirements, with the suggestion that one of the options will be selected to be taken forward in the Preferred Options. However, MacMic Group consider a mixture of options will be required to best deliver the growth needs of South Warwickshire as set out below. 30. Firstly, Table 7 of the SWLP Issues and Options document details the results of the high level testing of the five growth options in the supporting Sustainability Appraisal (SA, November 2022). This demonstrates that the five options perform differently in different areas, with no one option standing out as the best performing option across all areas. 31. Secondly, it is noted and considered important to remember that the assessment set out in the SA is provided at a high level, subject to several caveats, and without consideration of mitigation or deliverability. Options which score less favourably in the SA could therefore actually deliver more sustainable growth on closer examination. 32. The findings of the SA are important to guide decision making, but other matters such as the requirements of the NPPF should also guide the selection of the most appropriate growth strategy. This includes the requirement to deliver sufficient sites for the first five years of the Plan4 as required in the NPPF. 33. Finally, given the significant level of growth the SWLP will need to accommodate (see response to Issues H1 and H4 below) this is unlikely to be able to be met sustainably through a single growth strategy. 34. Specific support is provided for Option 1: Rail Corridors and Option 5: Dispersed. These options support growth at Kingswood which is considered appropriate given it is identified as a Growth Village in the adopted Warwick Local Plan (2017), has a range of local facilities and benefits from Lapworth Railway Station with direct connections to Birmingham, Leamington, London, Solihull, Stratford & Warwick, along with bus provision. Kingswood also has good accessibility to the highway network and is located within easy reach of the M42 and M40. Kingswood also has a strong functional relationship with the Greater Birmingham Housing Market Area, and growth here would be well placed to contribute towards unmet needs. To frustrate any further growth of Kingswood in the SWLP would not be consistent with the provisions of the NPPF. 35. MacMic Group consider that the omission of Kingswood from Option 2: Sustainable Travel is an anomaly given the settlement’s strong sustainable travel provision. 4 Paragraph 68 a) of the National Planning Policy Framework (July 2021)

67. 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. The Opportunity 68. 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). 69. 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 2019-2014. Kingswood is also accessible by a good highway network and is located within easy reach of the M42 and M40. 70. 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. 71. 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. 72. 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. 73. 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 transport15. 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. 74. 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. 75. 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. 76. 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. 77. 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. 14 Station Details – Housing around Rural Stations (russellcurtis.co.uk) https://ruralstations.russellcurtis.co.uk/index.php/station-details/?station_code=LPW 15 Paragraph 142 of the National Planning Policy Framework (July 2021)

91. Land at Station Lane, Kingswood, as identified in the attached Site Location Plan and on the Call for Sites Interactive Map (Site 169), is being promoted by MacMic Group to the SWLP. 92. Kingswood is considered to be an appropriate location for additional growth in the SWLP, noting its level of services and connectivity with nearby urban conurbations, including importantly by rail from Lapworth Railway Station. 93. A Concept Masterplan for the Land at Station Lane, Kingswood has been prepared; this details how the Site responds to the opportunities and constraints and could deliver around 125 dwellings, incorporating significant green infrastructure to retain the landscape character and historic environment setting. A suite of technical evidence base work has been prepared in support of the emerging proposals at Station Lane, Kingswood, including on highways and arboriculture. 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. 94. To bring forward Land at Station Lane, Kingswood in the SWLP would also be consistent with the emerging evidence base, noting that this area of the settlement is well connected and accessible to local services and facilities, including notably Lapworth Railway Station, and is an area of relatively low historic environment sensitivity. 95. Land at Station Lane, Kingswood is available in the short-term and is controlled by a single developer, MacMic Group, who are willing to support the SWLP process including through the preparation of a planning application to be submitted at an appropriate time as the SWLP progress, to provide comfort to the Examination Inspector that the site is deliverable. It is expected that the Site could sensitively deliver circa 125 dwellings, in a construction period of around 2.5 years, once planning permission is granted. 96. On the basis of the above, MacMic Group recommend that the SWLP allocates Land at Station Lane, Kingswood for development, in line with the provisions set out in the supporting Concept Masterplan.

Issue S2: Intensification: There are compelling reasons to have strong policies to support increasing active travel (cycling and walking), maintaining and improving public transport and local services and reducing the need to build on greenfield sites. Issue S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites. Issue S6: A review of Green Belt boundaries: The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives.

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? The approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. Q-S9: Please select the option which is most appropriate for South Warwickshire This new plan is the opportunity to review all settlement boundaries and ensure they are fit for purpose over the plan period. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Growth at existing settlements across the Joint Plan area should be a part of the overall Plan strategy and development should be located in sustainable settlements in additional to those proposed at Table 2, such as Stockton, given its existing range of services available. A wider list of sustainable settlements identified for growth will maintain and indeed encourage new and existing infrastructure requirements, jobs, services and a wider housing mix across South Warwickshire. Q-S4.2: Please add any comments you wish to make about the settlement analysis, indicating clearly which element of the assessment and which settlement(s) you are commenting on. Stockton is not included in the settlement analysis. It should be included in this assessment as the evidence base evolves to support the Plan.

Q-S3.1: Please add any comments you wish to make about the Urban Capacity Study After reviewing the consultation document, I feel this is heavily biased towards development in the Greenbelt area of North Leamington and this should at all costs be avoided, especially when only 1/3 of the plan area is greenbelt land. There should be a prioritisation of the use of Brownfield sites, and where this is not possible, development should not occur at all. In greenbelt areas. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non-greenbelt brownfield or greenfield sites, these should be actively sought out. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority and avoid any further damage to our areas of natural beauty and further harm to wildlife, enough of this has been caused by the creation of HS2. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? I believe that the growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure, this should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2: Do you think new settlements should be part of the overall strategy? I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate at all in greenbelt areas. I do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. Weston under Wetherley’s neighbouring village Hunningham floods several times a year, a concern is the water margin and drain off should more land be built on. Some of the smaller country lanes can be closed due to flooding, along with Offchurch, another neighbouring village. Fear of further flooding caused by further land being built on is a major concern. It must surely be acknowledged that the removal of further trees and hedgerows means less absorption into the ground, rising even further out water margin which will logically lead to further flooding within our area. Traffic pollution and noise will also become a contending factor to the surrounding villages should this proposal be allowed to commence. Our current infrastructure for the road system consists of country lanes that are often a one way approach, already making it difficult for 2 cars to pass each other. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt. As a resident of Weston under Wetherley, we moved to the area to walk in the countryside, breath fresh air, and enjoy the peace and quiet. We certainly pay for what you might class as ‘this privilege’ within the cost of our Council Tax and would be heartbroken should we be forced to move due to our surrounding area turning into a mini town, which is what will become of our village should this proposal be considered. Considering we are heading into a recession, would it not be wise to look at current abandoned properties (which there are plenty), and convert, which would surely be cheaper and cause less disruption to our already precious countryside and areas of natural beauty. We are being encouraged to ‘buy British’, but how can we when this will take up farming land, fields for livestock to graze etc? I work in the Agricultural industry, which is going through a hard enough time without further land being ripped away from our local farmers. Please, I beg of you, reconsider this proposal, England needs to remain green with pleasant pastures, something the children of the future can enjoy, and not become a concrete jungle.

Q-S5.2: Do you think new settlements should be part of the overall strategy? Yes. We support the consideration of new settlements as part of the overall strategy to ensure that South Warwickshire is able to meet their strategic objective of delivering homes to meet the needs of the whole community. New settlements are a sustainable way of providing high level of housing growth especially when located within close proximity to existing rail and highway infrastructure. []Lodge Farm, Earlswood is available and well placed to provide new housing development as a stand-alone allocation of circa 720 dwellings (at 40 dwellings per hectare) or as a larger new settlement with the adjoining landowners. The proposed allocation is located within the Bearley to Earlswood railway corridor area and is therefore considered to be a highly sustainable location for a new settlement. Q-S5.3 In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? We believe that the Council’s preferred approach focusing development within existing rail corridors is an appropriate one. South Warwickshire along with the rest of the UK has an over-reliance on private vehicles especially for travel to work and to access retail and leisure. To increase the number of residents utilising rail and other public transport methods new development should be located within close proximity to existing rail infrastructure making it more accessible and convenient. The north east of South Warwickshire has a concentration of existing railway stations and therefore provides the obvious location to focus new development. Land at Lodge Farm, Poolhead Lane, [] is centrally located between The Lakes and Earlswood stations which both provide regular services towards Stratford-upon-Avon and Kidderminster (via Birmingham). The Wood End station is additionally only 1.88km to the south east of the site. The site is also well located to junction 3 of the M42 and the A435.

Q-S9: Please select the option which is most appropriate for South Warwickshire Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. Terra consider that through developing the strategy for South Warwickshire, it will become apparent which settlement boundaries require reviewing. Therefore, Terra believe Option S9b would be the most appropriate strategy. The South Warwickshire Plan provides the opportunity to ensure that villages are well supported with a sufficient growth strategy. Boundaries for sustainable settlements, such as Bishop’s Itchington, should be reviewed and amended to support future growth.

Q-S5.2: Do you think new settlements should be part of the overall strategy? Terra believe that new settlements should be part of the overall strategy. Stratford-on-Avon have successfully delivered new settlements, such as Meon Vale, as part of their previous strategy and the new settlement at Lighthorne Heath/Gaydon is currently in development. Figure 1 demonstrates the location of Land east of Junction 12, M40 which is available for a new settlement. Terra would welcome the Councils to consider this location for providing a new settlement.

Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 – Dispersed Development. For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF “exceptional circumstances” principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 – Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there is ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 – Dispersed Development For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF “exceptional circumstances” principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt

Q-S3.2 Please select the option which is most appropriate for South Warwickshire Option S3.2c: None of these St Philips considers that the SWAs priority should be to direct development to the most sustainable locations. St Philips recognises that the NPPF places emphasis on the need to make as much use of brownfield land as possible, with paragraph 119 stating that: “Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.” Paragraph 120 of the NPPF continues by stating that “Planning policies and decisions should: • give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land; and • promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively.” However, it should be noted that whilst the use of brownfield sites is emphasised, there is a need to consider the NPPF as a whole. Paragraph 11a of the NPPF is clear that “all plans should promote a sustainable pattern of development”. In this regard, whilst suitable brownfield sites will often naturally emerge as sustainable locations for development, it is possible for greenfield land to provide a more sustainable location for development than unsuitable brownfield land. St Philips also notes that the SWLP ‘Urban Capacity Study (October 2022)’ has established that South Warwickshire is unlikely to be able to meet its development needs solely through the use of previously developed land.1 Therefore, regardless of the approach taken by the SWLP, there will still be a need to identify significant amounts of suitable greenfield land for development. 2.10 In this context, St Philips believes the Councils approach should emphasise sustainability, rather than arbitrarily prioritising brownfield sites over more sustainable greenfield locations. St Philips would therefore support the effective reuse of brownfield land alongside the release of greenfield land in sustainable locations as directed by the Settlement Hierarchy or through the delivery of a new settlement (subject to consideration of the delivery of core facilities and accessibility). Q-S5.2 Do you think new settlements should be part of the overall strategy? Yes As stated, the NPPF is clear that the supply of large numbers of new homes can often be best achieved through planning for larger-scale developments (Para 73). Importantly, it is also clear that plans should be prepared positively, in a way that is aspirational but deliverable (Para 16b), and should identify specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan (Para 68b). However, for a plan to be found ‘sound’, it must set out an appropriate strategy, taking account of reasonable alternatives, and be based on proportionate evidence (Para 35b). 2.17 In this regard, it is also important to note that the NPPF shifts the need to consider viability to the plan-making stage, requiring authorities to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability (Para 68). 2.18 The Planning Practise Guidance (PPG) provides further clarity for new settlements, stating that LPAs should demonstrate that there is a reasonable prospect that large scale developments can come forward. In particular, this should include a realistic assessment about the prospect of sites being developed and should engage with infrastructure providers to ensure that the infrastructure requirements are not beyond what could reasonably be considered to be achievable within the planned timescales. 2.19 St Philips therefore does not consider that new settlements are the panacea for housing delivery. Whilst the proposed SWLP plan period would extend up to 2050, and conceivably enable sufficient time for a new settlement to fully deliver, there are still legitimate issues regarding this type of housing delivery and the evidence required to successfully underpin a proposed allocation – notwithstanding that SOADC secured the allocation of Long Marston Airfield. In this regard, St Philips welcomes the Issues and Options’ (IO) recognition that whilst new settlements can be an effective way of delivering housing growth, further detailed assessment of the identified potential new settlement locations is required. The IO rightly acknowledges that “there is the possibility once these detailed assessments have taken place and in light of any comments received to the Issues and Options consultation, none of the potential locations are deemed suitable” (IO, page 49). 2.20 It is particularly important that, where new settlements are intended to be a large proportion of areas housing needs, there should be a robust – and proportionate – evidence base demonstrating that the site is deliverable. In the absence of this, there is a very real risk that a Local Plan could be found ‘unsound’ at examination. 2.21 Indeed, the examination of the North Essex Authorities’ [NEA] Section 1 Local Plan highlights the above issues. In particular, to meet housing needs over the 2013-2033 plan period, it proposed the allocation of three garden communities. However, the Inspector concluded that two of these proposed settlements should be deleted in order for the plan to proceed as they weren’t deliverable, on viability and infrastructure grounds. 2.22 Furthermore, at the examination of Hart District Council’s ‘Hart Local Plan (Strategy and Sites) 2032’, the Inspector’s concern was that the new settlement was being advanced as a long-term solution, but no alternatives to that option had been considered or properly tested in preparing the plan. The Inspector also noted that “there is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership” [IR63]. 2.23 In any event, the NPPF is clear that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed” (Para 60). As discussed, the NPPF emphasizes the importance of small-medium sites, stating that small and medium-sized sites can make an important contribution to meeting the housing requirement of an area, and are built out relatively quickly (Para 69). In this context, notwithstanding St Philips position on issues associated with pursuing New Settlements, the SWLP will need to allocate a variety of small-medium sized sites to deliver housing in the first 5-15 years of the plan period. Q-S7.2: For each growth option, please indicate whetheryou feel it is an appropriate strategy for South Warwickshire? The IO document states that development needs up until 2050 should be provided for within the most suitable and sustainable places. Key factors include the ability of new residents to integrate into existing communities with the ability to “access employment, education and the services they need; live healthy lives; and minimise dependence on the private car” (Page 57). In this context, the Issues and Options Consultation sets out five spatial Growth Options, comprising: a Option 1: Rail Corridors b Option 2: Sustainable Travel c Option 3: Economy d Option 4: Sustainable Travel and Economy e Option 5: Dispersed 2.25 The growth options listed above consists of individual but interconnected strategies which determine how much development will be directed towards the different settlements within South Warwickshire. The Issues and Options document states that “the strategy needs to be robust and flexible, in order to be of value for the whole plan period.” 2.26 In consideration of the above, St Philips believes that the spatial strategy must not entail a particular growth option (i.e. developing in close proximity of rail corridors). It is considered that the five growth options interconnect and in order to achieve the development needs within and beyond South Warwickshire up until 2050, a mix of options must be adopted. This would ensure a flexible and robust strategy that would disperse the benefits of growth between all of the settlements within the settlement hierarchy opposed to those that are considered to be the most sustainable in the eyes of a particular growth option. In this context, St Philips considers that a mix of the Growth Options will promote sustainable patterns of development across the area and align with the sustainability aspirations that are set out in the NPPF. 2.28 Some of the proposed spatial growth options have been brought forward from the Scoping Consultation, whilst others are hybrids of the previous options. St Philips considers that the current options should, in theory, allow the Issues and Options Consultation to consider how South Warwickshire could accommodate housing growth to meet its own housing needs, and a proportion of the C&WHMA and GBBHCMA’s unmet housing needs. 2.29 Nevertheless, St Philips considers that a mixed growth strategy, which combines severalgrowth options, will prove to be the best growth strategy for South Warwickshire. In this regard, St Philips notes that the ‘Sustainability Appraisal of the South Warwickshire Local Plan November 2022’ [“SA”] evaluates the 5 spatial growth options and concludes the following: “An overall best performing option is hard to identify. Option 5 is the worst performing option whilst Option 2 is likely to align most closely with development that will ultimately seek the most effective mitigation against climate change” (Para 7.15.2). The SA goes on to acknowledge that different options perform better for certain SA Objectives than others. St Philips also notes that the SA does not consider the potential for mitigation when evaluating the growth options, and that the scores are “strictly a guide and do not represent a diagnostic analysis” (Para 7.15.1). St Philips therefore considers that the SA is inconclusive regarding which of the growth options performs best. In this context, St Philips believes that the spatial strategy should not entail one particular growth option. It is considered that the five growth options interconnect, and in order to achieve the development needs within and beyond South Warwickshire up until 2050 a mixed strategy should be adopted. This would ensure a flexible and robust approach that would disperse the benefits of growth between all settlements within the South Warwickshire. Regardless of which growth strategy the Council pursues, St Philips considers that some development will likely need to be dispersed to ensure that the entirety of South Warwickshire benefits from housing growth. This is acknowledged within the ‘Evolving the Spatial Growth Options Topic Paper August 2022’ which sets out how the 7 high level spatial growth options presented in the Scoping Consultation evolved into the 5 options presented within the IO. The Topic Paper acknowledges in relation to Option 5 that “even if this option were not taken forward, some limited growth might still need to occur in some smaller settlements to support the overall sustainability of these places” (Appendix 2). Therefore, although Option 5 does not perform comparatively well within the SA and Estimation of Emissions Study, St Philips considers that it will be necessary to disperse some growth to support the sustainability of smaller settlements. On this basis, St Philips considers that a mix of the Growth Options will promote sustainable patterns of development across South Warwickshire and aligns with the sustainability aspirations that are set out in the NPPF. Whilst greater levels of development may need to be focussed on sustainable transport corridors, due to the level of infrastructure and services already present, it will also be necessary to direct growth to other settlements to ensure that the benefits of housing growth can be delivered in other parts of South Warwickshire. In particular, St Philips consider that there are several benefits to a mixed approach to the distribution of development: 1 It would support the well-being of those settlements that have the capacity to accommodate growth; 2 By concentrating development around existing and proposed new infrastructure it would also ensure that it benefits from a sustainable location with good access. Such an approach would allow the Council to capitalise on opportunities presented by existing or planned infrastructure when considering options for large scale new residential developments, in accordance with paragraph 73a of the NPPF; 3 When having regard to the need to release Green Belt land, such an approach would also be consistent paragraphs 141 and 142 of the NPPF: Where amendments to Green Belt boundaries are required, the promotion of sustainable patterns of development should be considered, alongside giving first consideration to land which is (inter alia) well-served by public transport (Paragraph 142); 4 It can ensure that a sufficient supply of homes, within close proximity to existing and future employment opportunities, contributes to an efficiently functioning economy. This can also aid in minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions); and 5 It would enable growth to meet the needs of neighbouring authorities to be located in an area close in proximity to where these needs arise. Similar to the above, this also has the added benefit of minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions). However, whilst the IO Consultation notes that many locations feature in more than one option, St Philips is concerned that Hockley Heath has been excluded from all Growth Options, including Growth Option 5. Whilst it is noted that Hockley Heath predominantly falls within Solihull Metropolitan Borough Council’s [SMBCs] administrative area, the edge of the settlement falls within WDC’s administrative area. Moreover, Hockley Heath is of a similar size and scale to Bishops Tachbrook – which is included in Growth Option 5 – and offers a similar variety of services and facilities. It should therefore not be excluded from consideration. Whilst the settlement is located on the edge of WDC’s administrative boundary, its role within South Warwickshire’s approach to meeting the Greater Birmingham and Black Country Housing Market Area’s (GBBCHMA) and Coventry’s unmet housing needs should nevertheless not be disregarded. Whilst there is no ‘unmet need’ in spatial planning terms to be accommodated from this neighbouring local authority, Solihull is nevertheless a core part of the GBBCHMA. There is a strong and cogent argument to meet the unmet housing needs of neighbouring authorities in area in close proximity to where these unmet needs have arisen. Hockley Heath lends itself well to this approach. This is because the settlements on the edge of WDC and SMBC, by virtue of their location and links, are generally ‘Solihull-facing’, rather than ‘South Warwickshire-facing’ (e.g. residents will look to Solihull for higher-order shops, services and facilities, as well as commuting to Solihull for work). This serves to highlight that parts of the SWLP area, particularly along the edge of SMBC, have stronger and more direct links to Solihull, and that capitalising on these links to address the GBBCHMA’s unmet housing needs is an entirely logical spatial approach to meet this challenge. At present, the Issues and Option’s proposed approach to Growth Option 5 disregards the role that Solihull’s ‘higher-order’ services have for the residents of settlements along South Warwickshire’s boundary. It therefore does not give adequate consideration to potential allocations sited at the edge of Solihull which would be expected to perform relatively well against most key sustainability criteria – such as Hockley Heath. 2.37 In addition to growth option 5, St Philips considers that Hockley Heath should also be included within growth option 2 (sustainable travel) given the settlement’s strategic location in relation to the bus and rail transport networks. As stated within the IO, growth option 2 is a hybrid of the rail corridor and main bus corridor options presented in the 2021 Scoping Consultation. As stated within the IO, option 2 will support and build on the strengths of growth option 1 (rail corridors) whilst recognising that in many parts of South Warwickshire, bus travel is the only accessible and viable option of sustainable transport. 2.38 In this respect, Hockley Heath provides the opportunity to achieve development which is suitably positioned to support the strategic bus network and encourage the use of sustainable modes of transport. As acknowledged by South Warwickshire during the 2021 Scoping Options Consultation, one of the main bus corridors passes through Henley-inArden travelling north over the M40 and through Hockley Heath, providing further opportunity to access larger settlements such as Solihull. This is presented by the figure below: This demonstrates that Hockley Heath is suitably located to distribute growth around a ‘main bus corridor’ and encourage the use of sustainable modes of travel. Hockley Heath should therefore be given sufficient consideration for inclusion within Growth Option 2. Additionally, Dorridge Train Station can be accessed from Hockley Heath within 13 minutes via bike, 7 minutes via the A8 bus service and 5 minutes by car. Dorridge Train Station provides a direct route into Solihull (8 minutes) providing residents with suitable access to additional services, amenities, and employment opportunities. In consideration, Hockley Heath is well positioned in relation to both the strategic bus and rail networks strengthening the case for inclusion within Growth Option 2. In addition to Growth Option 5, Bishop’s Tachbrook is also listed as a potential settlement which can meet the requirements of Growth Option 2. As previously acknowledged, this settlement is of a similar scale to Hockley Heath and provides a similar mix of services and facilities. In this regard, Hockley Heath should not be disregarded from growth options 2 and 5. Indeed, the NPPF is clear that, “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” (Para 59). It is also clear that the supply of large numbers of new homes can often be best achieved through sustainable urban extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (Para 72). In this context, paragraph 78 of the NPPF also states that: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.” St Philips therefore considers that the development on the edge of Hockley Heath lends itself well to achieving these objectives discussed, particularly given the fact that the site is well-located in order for residents to access a range of key local amenities and facilities. In addition, the settlement is well positioned in terms of the strategic transport network being in close proximity of the M40 and the M42, as well as the strategic rail and bus networks offering an optimal opportunity for achieving sustainable development. Stratford Road, Hockley Heath 2.43 As set out in Section 1.0 of these representations, St Philips is promoting land at Stratford Road, Hockley Heath, for residential development. Whilst part of the site falls within SMBC’s administrative area, the majority of the site lies within the administrative boundary of WDC. The site comprises 30ha of land and is located directly to the north east of Hockley Heath, in the Green Belt. Aylesbury Road (B4101) lies to the south of the site and Stratford Road (A3400) to the west. Bus stops on Stratford and Aylesbury Road, provide regular bus services that provide connections to key regional destinations including Birmingham, Stratford upon Avon and Solihull. The settlement benefits from a range of key local amenities and facilities, including the Hockley Heath village centre convenience store, a Post Office, Dental Surgery and Primary School. Development Potential 2.44 In terms of development within rural areas, paragraph 79 of the NPPF states: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.” 2.45 St Philips wishes to confirm the site’s status as being ‘suitable, available and achievable’. The site could provide approximately 28.3 ha of residential development, equating to approximately 280 new homes. The Vision Document, submitted in support of the Call for Sites form, demonstrates that the site could deliver an urban extension to Hockley Heath, a sustainable location for growth. The proposed development will not extend beyond the limits of this current development, and can provide visual buffer planting along the northern site edge to create a defensible boundary. 2.46 St Philips considers that the site presents an excellent location to deliver up to 280 dwellings, including up to 112 affordable dwellings. The scheme would sensitively respond to its surroundings; this would include measures to enable the protection and enhancement of the strong Green Infrastructure network. Connectivity through the site and to the village and surroundings would be emphasised to encourage sustainable travel. Green Belt Performance 2.47 As noted above, the site falls within the designated Green Belt. The NPPF is clear that the assessment of whether a site should be removed from the Green Belt is subject to a site's performance against the five purposes of the Green Belt (Para 138). To inform the Vision Document, St Philips has undertaken this analysis. The Vision Document demonstrates the site’s performance as follows: 1 Purpose 1: to check the unrestricted sprawl of large built-up areas – There is existing development to the south of the site in the form of residential properties that form ribbon development along Aylesbury Road and Stratford Road. The proposed development will not extend beyond the limits of this current development, and will provide visual buffer planting along the northern site edge to create a defensible boundary. The release of the land would not cause unrestricted sprawl towards Dorridge or cause westward sprawl. The site would therefore not make a major contribution to Purpose 1; 2 Purpose 2: to prevent neighbouring towns merging into one another – The nearest neighbouring settlement to the site and Hockley Heath is Dorridge to the northeast. Although the development would extend Hockley Heath in this direction, the permanent physical features bounding the site would not cause the gap between Dorridge and Hockley Heath to be adversely compromised. Indeed, it would still be a distance of over 1km. As such, the release of the Site would not cause Hockley Heath to merge with Dorridge; and 3 Purpose 3: to assist in safeguarding the countryside from encroachment – The development of the wider site would be a natural extension to the existing built-up area of Hockley Heath and is contained by permanent physical features, which would prevent encroachment into the wider countryside. As such, the new and proposed Green Belt boundary would not cause significant encroachment into the countryside. 2.48 In summary, the site is in a lower-performing area of Green Belt land which does not significantly contribute to the purposes of the Green Belt. A new Green Belt boundary could be established that would provide a visual buffer along the northern site edge. As such, St Philips consider that the release of the site from the Green Belt would be suitable and would accord with the NPPF. 2.49 In addition to the above, St Philips note that the NPPF does not require only the release of sites which perform the worst against the Green Belt purposes (i.e. low Green Belt harm). There is a need to consider the broader Green Belt policies in the NPPF as a whole. In this context, when reviewing sites within the Green Belt, the SWAs should have regard to whether the site would contribute towards the promotion of sustainable patterns of development, whether it has good access to public transport, whether compensatory improvements could offset the harm from its removal (Para 142), and the consistency of the Green Belt with the emerging Local Plan strategy. It is, therefore, an essential part of the exceptional circumstances test that Green Belt land that fulfils poor to moderate Green Belt purposes can be released if it is consistent with the Local Plan strategy for meeting requirements for sustainable development, for example, to secure more sustainable patterns of development. 2.50 In this regard, the site is located on the edge of Hockley Heath, a settlement which provides a range of services and facilities, which is located c.5 miles from Solihull, with a regular bus service running through the settlement providing connections to both Solihull and Stratford upon Avon. As a part of the development proposals, it is envisaged that that the existing semi-natural habitats within the site would be retained and the open space and Country Park could be delivered. This provides opportunities to enhance local biodiversity. 2.51 In consideration of identifying a suitable quantity of sites for meeting the development needs of South Warwickshire and the wider area, St Philips acknowledges that the Issues and Options document states the following: “Future capacity will have regard to both identified and windfall sites, and work is ongoing to assess the sites submitted in the 2021 ‘Call for Sites’ exercise in order to consider their availability, suitability and deliverability as part of the Housing and Economic Land Availability Assessment (HELAA).” 2.52 The Issues and Options document continues by stating: “From this it will be possible to identify the supply of specific sites and broad locations between years 1-5, 6-10 and where possible later years of the plan.” 2.53 St Philips considers that land at Stratford Road, Hockley Heath is a suitable and sustainable option for housing development and urges the Council to consider this site for development. A Call for Sites form was submitted in regard to land at Stratford Road, Hockley Heath during the 2021 consultation and as already stated, St Philips would like to highlight the site as being achievable, deliverable and available within the upcoming plan period. 2.54 In essence, the site is a highly sustainable location for growth, with access to services and facilities and public transport. It is also well placed to meet the GBBCHMA’s unmet needs in close proximity to where they arise, given its proximity to Solihull. The delivery of environmental enhancements on-site, which would be achieved as part of the development, would ensure that any harm arising as a result of the removal of the site from the Green Belt could be offset.