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

Great care needs to be exercised though, to ensure that all development proposals, suit the location, for size, style, volume and character. The development should enhance the existing development and provide benefits for the whole community. Again Developers need to be carefully managed to ensure that their proposals are 'best fit' for the existing town or village.

[RE growth of existing settlements] Dependent on settlement and situation - a single approach cannot be taken. Hamlets, or small rural villages must be protected at all costs.

The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land Argument 5. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. Argument 6. It is not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (See letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints” (see letter above). The utility of the Green Belt around North Leamington is a genuine constraint on development.

Sensitive growth of existing settlements will have to be part of any strategy to have large numbers of new properties, as dictated by central government. We agree with the arguments presented in this consultation for “Market Towns of sufficient size to become a complete and compact 20-minute neighbourhood.” This approach is more feasible than focussing on active travel arrangements between rural communities, although that too is desirable.

I understand the need for local authorities to be looking and planning to the future, but I also understand the need to retain elements of village life which are so important to existing residents. Wootton Wawen is an independent historic community which lies within the Green Belt and the Arden Special Landscape Area. The last published Census figures show the population to be 1,318 in 2011 with almost 50% of residents living in “park homes”. The SWLP indicates that Wootton Wawen could see up to 500 new homes be built within the village boundary, this could potentially almost double the size of the population and more than double the amount of houses in the village which would surely put overwhelming demand on the existing infrastructure giving rise for concerns over highway safety along with traffic and noise issues. As previously mentioned Wootton Wawen is washed over by Green Belt with generally open and important views in many directions. Wildlife is varied and plentiful. As I understand England has around 6,324 sq miles of Green Belt which equates to just 12.6% of England, such a small overall percentage which needs to be preserved for future generations. I also note the recent announcement by the Government of changes to the national planning policy suggesting that local authorities will not be required to review and alter Green Belt boundaries to meet housing needs in full for their Plan. This announcement may well have come after the SWLP was compiled. The Stratford upon Avon to Birmingham railway line has long been regarded as an unofficial boundary line to retain any development to the eastern side of the line and thus prevent any intrusion into the Green Belt and therefore condense any possibility of urban sprawl. At this stage I understand that specific sites are not for discussion but if Wootton is to expand there are geographic areas that would link two parts of the village better than extending beyond the railway boundary and into the Green Belt. Wootton has suffered many times from the issues of flooding. Serious consideration must be given to the possibility of any future development increasing the prospect of further flooding if valuable agricultural land which currently acts as a natural soak away is to be developed. There are limited Brownfield Sites within the village boundary but surely these are areas that should be explored and encouraged for development before any thoughts of extending the village boundary.

I write to register my comments on the current South Warwickshire Local Plan, as detailed above. I wish to object to the changes to Green Belt Boundaries around Leamington Spa, where I have grown up over the last 25 years. I am concerned that the Green Belt is not given sufficient weight in the Issues and Options Consultation on the South Warwickshire Local Plan. In my opinion, the Green Belt around the North of Leamington fulfils all of the five stated purposes of Green Belt land. The Government has recently made it clear in a letter from the Secretary of State for Levelling Up, Housing and Communities, that local planning authorities such as Warwick District Council are not expected to review the Green Belt to deliver housing. Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is, to quote the letter from Michael Gove MP “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The Green Belt around North Leamington is recognised as a genuine constraint to development. One of the most important reasons for a Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land and the Secretary of State’s letter in December also made a “brownfield first” pledge which should be the basis of the way that a District Council such as Warwick responds to unmet housing need in other neighbouring authorities. So, the “brownfield first” pledge should be reflected in any duty to cooperate with other local authorities, ensuring that larger conurbations do look hard at creative brownfield solutions close to where people work. Developers may well prefer to use greenfield sites as these are easier to develop, but that appears to go against the latest Government advice. I am also concerned about the statistics in Chapter 4, issue S6 that state that 54% of respondents to the first consultation, Scoping and Call for Sites, supported “exploration for growth opportunities” in the Green Belt. The planning team appear to be using this as one of the justifications for reviewing Green Belt boundaries. However, I believe some 35% of respondents to that consultation were developers and 10% were businesses or landowners, suggesting that only a small proportion of other respondents were in favour. The heavy weighting towards groups with vested interests should be treated with caution and certainly not used as justification. The letter from the Secretary of State does in itself justify halting the current work on the South Warwickshire Local Plan until the updated NPPF is finalised. This would enable the South Warwickshire Local Plan to be realigned with the Government’s clear intention for planning authorities to have more power to resist identifying Green Belt land for development if the only solution for meeting assessed housing need would be to build on Green Belt land. The Green Belt around the North of Leamington is a highly valued open space. As a local resident I have, over many years and continuing to this day, found these spaces very valuable both in terms of my physical and mental health. I would also comment that whenever I see or use these spaces, it is rare not to find other members of the public using the space for walking, running, dog-walking, bird-watching etc. It is visually of a very high quality and has a number of easily accessible public footpaths across the fields. When walking these footpaths I have enjoyed seeing a wide variety of local wildlife, including deer, badgers, buzzards, red kites and woodpeckers to name but a few. These footpaths were heavily used during lockdown, and the gratitude that residents felt to the local farmer for his understanding was evidenced by the thousands of pounds raised for the charity of his choice. The farmland is high-quality agricultural land and makes an important contribution to sustainability and security of food supply. I believe that this is a critical issue for this country going forward and a major reason for preserving green belt agricultural land. It is also to be noted that recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The Government is clear that it seeks to protect such land from non-agricultural development, and indeed the National Planning Policy Framework states, “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality”. The agricultural land provides rural employment and the mixed arable, grazing and wildlife refuge all helps to maintain the wonderful ambience of the rural village of Old Milverton only a short distance from Leamington Spa, but with a totally rural feel. Development within the Green Belt to the north of Leamington Spa would substantially reduce the land that separates the distinctly different towns of Kenilworth and Leamington Spa. This is even more the case since the current Local Plan, which in reviewing the Green Belt removed land to the south of Kenilworth and north of the A46 from the Green Belt. The joint Green Belt study in 2015 highlighted the contribution to preventing the merger of Leamington Spa, Kenilworth and Coventry that this part of the Green Belt makes by stopping urban sprawl, protecting the countryside and preserving the special character of these differing but very special historic towns. The routeing of HS2 in this area has also had a significant negative impact on Green Belt space in this area. The Planning Inspector’s 2017 response to the current Warwick District Local Plan states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p18, para 91). It also points out that: “Development to the land in question would involve a substantial expansion of the built-up area into currently open countryside to the north of Leamington Spa. It would have significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p34, para 201). The construction of HS2 has made the existing Green Belt even more valuable and the Inspector’s wise comments are indeed more relevant now, than they were in 2017. There is concern that the assessments of the two proposed development sites are in the 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both assessments state that the locations would be “unlikely to lead to coalescence of settlements”. However, any development would join Old Milverton and Blackdown to Leamington Spa and bring Leamington Spa close to the southern suburbs of Kenilworth. The Green Belt has a major purpose in stemming the loss of open space between the West Midlands, a major urban conurbation, and neighbouring towns and villages. The proposed developments would significantly reduce that green corridor, and have a detrimental impact. The officers have done considerable work on the Issues and Options consultation of the South Warwickshire Local Plan, but sadly the process is flawed because all five spatial growth options involve some development in the Green Belt. It is even more unfortunate that all of them refer to the Green Belt to the North of Leamington as an area of ‘significant urban extension’. This all appears to ignore the legitimate function served by the Green Belt, and is contrary to very recent Government announcements, the 2015 green belt review and the detailed 2017 response by the Planning Inspector.

Feedback on planning consultation for Henley in Arden 1. Initially the incorrect area to target it would be more suitable infill in brownfield sites available with better infrastructure links better to Focus on more suitable areas within South Warwickshire such as the golf course at the Northern end of the village or Bear lane 2. Green belt – the maintenance of the green belt should be upheld for conservation reasons such as wildlife conservation and other environmental reasons such as flooding . This plan Creates a dangerous precedent in the erosion of green belt which is for Community benefit one of the key purposes of greenbelt. The green belt areas currently have a Positive environmental impact I.e . Henley is prone to flooding. 3. Infrastructure: air quality and pollution, sewage system, road quality, traffic, parking, M40 closure impact, poor bus links, roads unable to be widened due to listed properties are many reasons why wholesale development in Henley should be avoided.Future proofing the infrastructure is not considered at the health, schooling and environmental changes would be socially and economically unviable 4. Local social services are already overwhelmed and would need significant changes to accommodate such an increase in population 5. Focus on localism: henley’s character would be changed and the local towns historical heritage (changing rural nature of a historical town – e.g. Solihull poor example), would be lost Stratford is an example of this. The local services are at capacity, proportional expansion, would be more suitable 6. Existing brownfield infill within the village has occurred over previous years without any improvement in the infrastructure within the local area (look at population growth in the local area through the consensus). Specific examples: the market, goldsmiths, water gardens – cross reference with neighbourhood plan leaving the town overstretched

I wish to comment on the above plan with respect to the proposed new housing in Henley in Arden I am in favour of new housing in Henley in Arden. There is a clear demand for housing in Henley. New and existing houses sell very quickly. However at the moment new housing is restricted to conversion of existing properties into high value apartments, small industrial units also being developed into high value apartments and properties being built in gardens. There is no land available for any small scale developments and consequently no opportunity for entry and family housing On the other hand there is a lot of unused land around Henley, particular to the east beyond the railway line. Although the farmland is probable green belt most of it is unused agricultural land and a non functioning, failed golf course. Developing to the east of Henley would enable new road and services infrastructure to be developed without significant impact on the existing town activity.

The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. Argument 6. It is not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (See letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints” (see letter above). The utility of the Green Belt around North Leamington is a genuine constraint on development.

Not sure you should be allowing more development in Whitnash due to transport and road usage being heavily used at peak with no opportunity for road widening etc

Growth will likely be necessary but should be supported by a housing need analysis which reflects national policy. Local authorities are expected to take into account genuine constraints and given the purpose of the green belt which would be undermined by development of the proposed sites in North Leamington this should be treated as a constraint and those sites removed as options. Given less than six years ago similar proposals were rejected there seems no sense in revisiting the same decisions, particularly without a housing need analysis.

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

I am commenting on the settlements of Leamington Spa and Warwick. The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. The proposals relating to this issue are not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The utility of the Green Belt around North Leamington is a genuine constraint on development.

There is no need to grow or develop Old Milverton and Blackdown, or attempt to merge them with Leamington Spa or Kenilworth. The green belt is a protected area for a reason. It is to stop the co-alessing of small settlements and keep a character to where people choose to live. Infra structure to urban sites are adequate for the number of houses already there. Hundreds of houses need roads, pavements, sewage and schools, to name just a few amenities ed. These cannot be adequately access if the process has not been thought out. Green belt is there for a reason.

Despite answering “No” to S4.1 above and as stated in in my comment on 3.1 above I believe Brownfield sites within existing settlements should be prioritised, especially infilling and change of use. (eg: retail to residential). Growth is inevitable and should be supported by local housing needs analysis reflecting national policy. North Leamington Green Belt land has genuine constraints restricting development and fulfils the five purposes of Green Belt land, namely : - ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. It is less than six years ago that similar proposals were rejected. The Planning Inspector’s 2017 response to the existing Local Plan for Warwick District stated the need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built-up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). The openness and character of this area has already suffered significant damage with the construction of the HS2 railway line adversely affecting farmland and wildlife habitat. This would only be exacerbated with further development in the area, compounding the significant adverse impacts the Planning Inspector referred to in 2017. I believe the arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago. This option is contrary to Government policy which recently made clear Local Planning Authorities are not expected to review the Green Belt to deliver housing. Changes to the NPPF mean that the estimated figure for Local Housing Need is only a starting point and where genuine constraints exist, (the Green Belt around North Leamington is such a genuine constraint) areas will not be expected to meet this need.

Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? • We do not consider that exceptional circumstances exist to justify the release of Green Belt land to expand existing settlement boundaries. Green Belt land in Kenilworth in these broad locations, and particularly in Kenilworth South fulfils important functions in terms of openness / landscape character, coalescence with Coventry to the North, Leek Wootton and onwards to Warwick to the South, and making a significant contribution to the area’s biodiversity and to the recreation and wellbeing of the community. • Brownfield sites and under-utilised existing residential areas (with the potential for higher density housing) should be priorities. We would strongly challenge the basis for releasing areas of Green Belt at all over extensions to villages, brownfield sites and new communities etc, particularly in this area where Green Belt land fulfils this important separation function.

Despite answering “No” to S4.1 above and as stated in in my comment on 3.1 above I believe Brownfield sites within existing settlements should be prioritised, especially infilling and change of use. (eg: retail to residential). Growth is inevitable and should be supported by local housing needs analysis reflecting national policy. North Leamington Green Belt land has genuine constraints restricting development and fulfils the five purposes of Green Belt land, namely : - ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. It is less than six years ago that similar proposals were rejected. The Planning Inspector’s 2017 response to the existing Local Plan for Warwick District stated the need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built-up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). The openness and character of this area has already suffered significant damage with the construction of the HS2 railway line adversely affecting farmland and wildlife habitat. This would only be exacerbated with further development in the area, compounding the significant adverse impacts the Planning Inspector referred to in 2017. I believe the arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago. This option is contrary to Government policy which recently made clear Local Planning Authorities are not expected to review the Green Belt to deliver housing. Changes to the NPPF mean that the estimated figure for Local Housing Need is only a starting point and where genuine constraints exist, (the Green Belt around North Leamington is such a genuine constraint) areas will not be expected to meet this need.

Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made.

The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (See letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints” (see letter above). The utility of the Green Belt around North Leamington is a genuine constraint on development.

In recent years Warwick, Leamington, Whitnash, Kenilworth and South Coventry have experienced significant developments of new housing estates on their perimeters. The first three towns have already merged together and Kenilworth is in danger of being merged with Coventry and Leek Wooton. Indeed, looking at your plans it looks like a huge continuous conurbation could be formed as the green belts are chipped away. This will greatly mar the lives of the many thousands of EXISTING residents. This is a fact - how could new housing developments improve the existing residents lives? The unique character of these once distinct communities is being eaten away. Kenilworth has suffered enough from HS2 and the loss of our precious ancient woodland without adding insult to injury by earmarking land for development both sides of the new train track. Kenilworth is a really nice place to live, it isn't so big that you feel anonymous and powerless. There is a sense of community and a low crime rate. Increasing it's size with new housing estates could easily irreversibly change it's character, sense of identity and community cohesion. I am strongly opposed to the land marked for development on your plan. People in Kenilworth enjoy living in a small town that has one foot firmly rooted in the countryside. There are a large number of people that enjoy daily countryside walks directly from their homes. This is essential for their physical and mental wellbeing. Surrounding Kenilworth with a suburb of estates could make this impossible. I am very strongly opposed to further growth of existing settlements arou

The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: 1. check the unrestricted sprawl of large built-up areas 2. prevent neighbouring towns merging into one another 3. assist in safeguarding the countryside from encroachment 4. preserve the setting and special character of historic towns 5. assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. It is not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (See letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints” (see letter above). The utility of the Green Belt around North Leamington is a genuine constraint on development.

Growth will be necessary but should be supported by a locally agreed housing need analysis which reflects national policy. Land in the North Leamington Green Belt should not be developed because local authorities are not expected to meet local housing need where there are genuine constraints, including green belt constraints. There are lots of positive reasons for protecting the Green Belt and any development would be costly and detrimental overall. The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of thearea” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. It is not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (See letter from the Secretary of State for Levelling Up, Housing & Communities attached.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints” (see letter above). The utility of the Green Belt around North Leamington is a genuine constraint on development.

Concerning arguments 1, 5 and 6, greenbelt constraints should trump the need for local housing, thus land in the North Leamington Green Belt should not be developed. Protecting the green belt is important to keep the separate identity of distinct settlements and prevent Leamington being subsumed into Greater Coventry, as well as the need for recreational space for residents in open nature.

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.

Growth of existing settlements should only be considered where it does not require greenbelt development. Previous growth of existing settlements in non-greenbelt land should not prevent further development and infrastructure should be invested in 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.

I am commenting on the settlements of Leamington Spa and Warwick. The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. The proposals relating to this issue are not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The utility of the Green Belt around North Leamington is a genuine constraint on development.

I am commenting on the settlements of Leamington Spa and Warwick. The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. The proposals relating to this issue are not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The utility of the Green Belt around North Leamington is a genuine constraint on development.

Q-S1. Please select the option which is most appropriate for South Warwickshire Option S1a. It is vitally important that the South Warwickshire Local Plan addresses and facilitates nature recovery straight away rather than waiting until a Local Nature Recovery Strategy (LNRS) is adopted. The Local Plan policy (and supporting text) should refer to the forthcoming LNRS and, ideally, should explicitly put measures in place to incorporate the LNRS into the Local Plan once the LNRS is adopted. As indicated in the consultation documents, the existing Warwickshire, Coventry and Solihull Sub-regional Green Infrastructure Study can be used to inform the green / blue infrastructure policies. Consideration should also be given to other relevant guidance and policy measures including: • The Government’s aspiration to ensure that 30% of land is managed for nature by 2030.4 • The Government’s Environmental Improvement Plan 2023,5 including the targets to: o restore or create 500,000 hectares of wildlife rich habitat by 2042; o increase tree canopy and woodland cover from 15.4% to 16.5% of total land area in England by 2050. • Natural England’s Green Infrastructure Framework;6 • South Warwickshire Climate Action Support,7 including the target to increase forest coverage by 24% by 2030. • The Cotswolds Nature Recovery Plan.8 4 https://www.gov.uk/government/news/pm-commits-to-protect-30-of-uk-land-in-boost-for-biodiversity 5 HM Government (2023) Environmental Improvement Plan 2023 6 https://designatedsites.naturalengland.org.uk/GreenInfrastructure/Home.aspx 7 Warwick and Stratford-on-Avon District Councils (2021) South Warwickshire Climate Action Support 8 Cotswolds National Landscape Board (2022) Cotswolds Nature Recovery Plan Q-S2. Please select all options which are appropriate for South Warwickshire Option S2a. Intensification of development provides significant potential benefits. For example, it can help to increase the number of people who live within, say, a 10-minute walk, of key services, facilities, employment opportunities and public transport options. 9 This, in turn, should help to reduce the need to travel by car and, in doing so, help to reduce greenhouse gas emissions. However, the capacity of different settlements to accommodate intensification of development will depend on the character of the individual settlement. As such, it is important to develop design codes for each character area. Intensification should not be delivered at the expense of green infrastructure, including biodiversity, or to the detriment of historic environment designations (and their settings) such as Conservation Areas, listed buildings and scheduled monuments. If intensification is being considered within the Cotswolds National Landscape and its setting, this should not be to the detriment of the natural beauty of the National Landscape, including its special qualities, local distinctiveness and views from (and to) the National Landscape. 9 This concept is commonly referred to as the ’20-minute neighbourhood’ Q-S3.2. Please select the option which is most appropriate for South Warwickshire Option S3.2a. The need for development to be in a sustainable location is more important than the principle of prioritising development on brownfield land. This is because the sustainability of the location (i.e., proximity to services, facilities, employment and public transport) is a key component of mitigating the impacts of climate change. Developing brownfield land that is not in a sustainable location is likely to result in higher levels of greenhouse gas emissions (for example, through car use) than development in a sustainable location. Q-S4.1. Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes. This growth should be focussed on those settlements / neighbourhoods that are – or have the potential to become - ’20-minute neighbourhoods’, providing key services and facilities. Q-S5.2. Do you think new settlements should be part of the overall strategy? Yes. New settlements (away from protected landscapes) have the potential to play a key role in helping to secure ’20-minute neighbourhoods’ and, in doing so, help to reduce greenhouse gas emissions relating to commuting, for example. Q-S7.2. For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: • Option 1: Rail Corridors: Neutral • Option 2: Sustainable Travel: Neutral • Option 3: Economy: Neutral • Option 4: Sustainable Travel and Economy: Appropriate strategy • Option 5: Dispersed: Inappropriate strategy. A key consideration in identifying the most appropriate growth option is the greenhouse gas emissions that will result from each option and the extent to which each option helps to mitigate and adapt to the impacts of climate change. As outlined in response to Question Q-S5.3, the ‘sustainable travel and economy’ growth option appears to perform the best in this regard. Options 1-3 also provide some benefits, in this regard, as they locate development close to public transport or employment. Option 5 (Dispersed) clearly performs the worst in relation to greenhouse gas emissions. It is more difficult to identify a clear preference based on the results of the Sustainability Appraisal12, although Option 5 (Dispersed), again, clearly performs the worst in this regard. The Sustainability Appraisal indicates that Option 5 (Dispersed) performs relatively well in relation to ‘Sustainability Appraisal Objective 4: Landscape’ on the basis of the overall scale of development being more thinly spread and distributed. However, this does not take into account the fact that Option 5 would result in considerably more development within and adjacent to the Cotswolds National Landscape.13 For example, Options 1-5 don’t indicate any growth (over 50 dwellings) in settlements within the Cotswolds National Landscape, whereas Option 5 would result in: • 150-350 dwellings in one National Landscape settlement (Ilmington); • 50-150 dwellings in each of five National Landscape settlements; • 150-350 dwellings in a settlement adjacent to the National Landscape (Quinton); • 50-150 dwellings in each of two settlements adjacent to the National Landscape (Tysoe and Great Wolford). This scale of development would not be appropriate in these relatively small settlements given that national planning policy states that the scale and extent of development in AONBs should be limited. This scale of development is also likely to harm the character, local distinctiveness and natural beauty of these settlements. This should not be taken to mean that we think that there should be no development within the Cotswolds National Landscape. It just means that the relatively small settlements in (and directly adjacent to) this part of the Cotswolds National Landscape are unlikely to be suitable areas for accommodating 50+ dwellings. See our response to Question Q-S8.1, below, for further comments on this issue. All five growth options identify that 5,000+ dwellings would be provided at Long Marston Airfield / Meon Vale. It would be useful if a more exact figure could be provided for each of the growth options as this would help with identifying the potential impacts of this development on the Cotswolds National Landscape. Further recommendations in relation to this development are provided in response to Question Q-S5.3. 12 A summary of the sustainability appraisal for the five growth options is provided in Table 7 of the Issues & Options consultation document (pages 59-60). 13 Option 5 is shown in Figure 20 of the Issues & Options consultation document (page 72). 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? No, we do not think that a threshold approach is appropriate. With regard to potential development within the Cotswolds National Landscape, we recognise that the Cotswolds is a living and working landscape and that maintaining thriving local communities is essential to the long-term future of the National Landscape. Providing housing that meets the needs of the local communities within the Cotswolds National Landscape plays an important role in achieving these aspirations. However, these aspirations should be delivered in a way that is compatible with and, ideally, positively contributes to the statutory purpose of conserving and enhancing the natural beauty of the National Landscape. Housing delivery within the National Landscape should also focus on meeting affordable housing needs, particularly with regards to housing that is affordable in perpetuity, such as social rented housing. Windfall housing proposals outside the settlement boundaries should be based on robust evidence of need arising within the National Landscape, for example, a housing needs survey for the specific settlement / parish. Further guidance on this topic is provided in the Board’s Housing Position Statement.14 In the current Stratford-on-Avon Core Strategy, the hamlet of Upper Quinton, which lies within the Cotswolds National Landscape, is included within the Local Service Village boundary for Lower Quinton, which lies outside of the National Landscape. We do not think that this is appropriate. Government guidance states that AONBs ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’.15 In the context of Quinton, this means that Upper Quinton is unlikely to be a suitable area for accommodating the housing needs associated with Lower Quinton, which is a much larger settlement than Upper Quinton. 14 Cotswolds National Landscape Board (2021) Housing Position Statement 15 https://www.gov.uk/guidance/natural-environment#landscape. Paragraph 041. Q-S8.2. For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? As indicated in response to Question Q-S8.2, we do not think that a threshold approach is appropriate. However, it is worth noting that the issue of thresholds is relevant when considering whether a proposed development within the Cotswolds National Landscape constitutes ‘major development’, in the context of paragraph 177 of the National Planning Policy Framework (NPPF). The Board’s Landscape-led Development Position Statement16 provides a checklist of topics that should be taken into account when deciding if a proposal constitutes major development. One of the considerations in the checklist is whether a proposed housing development would increase the size of a settlement – or increase the number of dwellings in a settlement - by more than 5%. As such, if a proposed development would increase the number of dwellings by more than 5%, this makes it more likely that the proposal would constitute major development. 16 Cotswolds National Landscape Board (2021) Landscape-led Development Position Statement. See Appendix 5, including footnote 36. Question Q-S9. Please select the option which is most appropriate for South Warwickshire Option S9a would be most appropriate as this would enable the settlement boundaries to be finalised once any non-strategic allocations have been identified and taken forward.

I am commenting on the settlements of Leamington Spa and Warwick. The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Similar proposals were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. The proposals relating to this issue are not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. (letter from the Secretary of State for Levelling Up, Housing & Communities.) Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The utility of the Green Belt around North Leamington is a genuine constraint on development.