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

Surprise surprise because of the green belt all the development in the last local plan was in South Leamington near Bishops Tachbrook. Apparently we had to take Coventry's overspill yet those houses were built in south Leamington which is miles away from Coventry and clogs up the roads with those people trying to commute back to Coventry. There MUST be green belt development to balance out the development across Warwick and Leamington. The south is full, it can take no more developments. The infrastructure is over capacity. Drive around at rush hour, try getting a doctor's appointment or a place for your child at the local school. It's an absolute nightmare. The green belt needs to be built on to ease the pressure on the south of Leamington.

There is no comments section for Q6 so I am commenting here instead for the green belt issues. I need to give some comments about land which is specifically going to be put forward into the call to sites plan which directly affects the village of Hockley Heath and our development on Aylesbury Road. Greenbelt should be preserved from development, giving green space to the future is an imperative. Too much greenery is spoiled by development choices in and around Solihull. In particular, there is land just off the Aylesbury Road that has been bought for development and now due to perceived challenges with the Highways agency, it is being put into the Call to Sites plan. This land should not be developed for a number of reasons but mainly as follows : 1. the imminent danger there would be from the speeding traffic on the Aylesbury Road (access issues and safety)- a fact that this is a busy road, a number of deer have been hit by speeding cars in the last few months, a dog was killed and there is an accident waiting to happen here. Highways Agency has previously declined approval for developments off this stretch of land in previous planning applications - assume that the planning agency acting on the landowner's behalf has come to the same conclusion and is now seeking to put this forward as part of the SWLP. If this was to be successful it would also mean lapworth and hockley heath would merge into one sprawling area and have no visible boundary line 2. lack of infrastructure in Hockley Heath village as the nearest village to this point - the school is over subscribed, not sufficient resources to accommodate a new population arriving - the village is creaking at the seams since it was never meant to be larger and no infrastructure investment has been made for a very long time 3. desecration of the local wildlife in that field - the field is well used by dog walkers and generally by people walking to enjoy the landscape, it would be detrimental to wildlife 4. greenbelt land itself should be preserved

As there is no comment box for Q6 I would like to comment here on Green Belt issues. These are regarding land which will be put forward into the second Call for Sites. 1. This affects the village of Hockley Heath and the Aylesbury Court development. This piece of land provides a natural habitat for many and varied species of birds and animals. These green spaces offer excellent corridors for wildlife to travel through. In addition to this increased traffic on Aylesbury Road to and from Hockley Heath will result in higher emissions and reduced quality of air. 2. Access to the site would be problematic and dangerous. It would appear that planning for this site has been rejected on previous occasions and is now being put forward as part of the SWLP. 3. With regard to Hockley Heath village there has been little infrastructure input and therefore it would seem entirely unsuitable for further development to take place on Aylesbury Road. 4. Green Belt land should only be used as a last resort after all other options have been explored and utilised.

1. USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: The proposed development in Henley-in-Arden uses development in the Green Belt incorrectly to resolve structural planning problems in the district. 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: The bus and train infrastructure is barely sufficient 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 25 incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all of 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 1. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Center 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 likely 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.

Warwickshire has been impacted massively by the HS2 build in terms of disruption to everyday life, long term environmental damage and loss of character. This especially applies to woodlands and park land. There should be no new housing in areas impacted severely by HS2 e.g. within 5km of the line.

Warwickshire has been impacted massively by the HS2 build in terms of disruption to everyday life, long term environmental damage and loss of character. This especially applies to woodlands and park land. There should be no new housing in areas impacted severely by HS2 e.g. within 5km of the line.

A threshold approach to small scale development is inappropriate in greenbelt areas, nor should the plan 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 around Hunningham 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. As mentioned above, this is a fallacious argument, because preservation of the greenbelt contributes positively to reducing the impacts of climate change. 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, especially when this can be used as a means of permitting development in what would have otherwise been greenbelt . 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. Given the very small number of respondents, is it possible that these were from developers or others who would benefit from such development, as I note that there were almost as many sites submitted as responses received? The tiny number of respondents should therefore not be used as a basis for decision making and should not be used to justify development or a review of the greenbelt.

Please find below my response to the issue and options consultation process. There are significant concerns associated with development with Henley In Arden and these are outlined below in more detail. 1. USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: The proposed development in Henley-in-Arden uses development in the Green Belt incorrectly to resolve structural planning problems in the district. 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: The bus and train infrastructure is barely sufficient 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 25 incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all of 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 1. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Center 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 likely 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.

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. The option presented in the consultation is not in accordance with the NPPF's avoidance of greenbelt development except in exceptional circumstances and is in my personal opinion misleading. 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. The option presented in the consultation is not in accordance with the NPPF's avoidance of greenbelt development except in exceptional circumstances and is in my personal opinion misleading. 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 given viable alternatives. The option presented in the consultation is not in accordance with the NPPF's avoidance of greenbelt development except in exceptional circumstances and is in my personal opinion misleading. Q-S7.2 –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. I 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. Development in the North Leamington Greenbelt was proposed in the last WDC local plan and had to be withdrawn, with significant consequences. I feel that the climate emergency might be used to artificially find a different approach to justifying exceptional circumstances, I strongly oppose this as I feel there is no grounding to this approach. 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. Finally, the appendices to the document suggest that extension of Cubbington into greenbelt would have a low risk of urban sprawl, I feel this is incorrect and should be revised. The greenbelt between leamington and Coventry is under significant pressure and already shrinking, I would strongly argue that further development is a significant risk for urban sprawl and certainly the perception of urban sprawl.

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: We 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. We feel that there is substantial scope to include development alongside rail corridors outside of the greenbelt. 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 –For the remaining spatial growth options, we 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: We 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: We are 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). We 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.

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.

Issue B1: Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

Issue S3 – Using Brownfield Land for development We support the re-use of brownfield land for new development as an effective use of land. Through the NPPF 2021, the Government confirmed its commitment to delivering new housing on brownfield land. NPPF paragraph 85 sets out that: “The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.” The importance placed on the development of brownfield land was highlighted through the introduction of a £1.8bn brownfield fund in late 2021, and subsequently referred to within the NPPF consultation launched in December 2022 which considers that: “In support of levelling up, the UK government will target the majority of delivery on brownfield sites outside London and the south east. As part of the wider Framework review, we therefore want to make sure that national planning policies are fully supportive of our aim to gently densify our urban centres, especially outside London and the south east.” Long Marston Airfield is classified as Previously Developed Land (PDL) and is a ‘brownfield’ site allocated to be brought forward for development within SoA’s Core Strategy 2011-2031 with an accompanying Framework Masterplan SPD (February 2018) to guide its delivery. It should be seen as a cornerstone of any spatial strategy proposed as part of the SWLP and in the context of national policy, it is imperative it continues to be allocated as a key location for growth, consistent with its existing status in the Core Strategy. Q-S7.2 – For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: The vision for South Warwickshire places particular emphasis on the need for sustainable development and the need to consider active travel and the ability to connect development to public transport. Therefore, whilst Cala does not consider at this stage that there is sufficient evidence to make a judgement on the most appropriate growth option, it is clear that a balance needs to be found between facilitating appropriate growth across South Warwickshire in order to both meet future housing need and respective local employment growth, whilst ensuring that design standards and sustainability maintain a high priority. The Council will need to consider, with its neighbouring authorities, how much of the Greater Birmingham unmet housing need it can accommodate, and how that influences the necessary growth options. The growth options will need to consider the number of homes South Warwickshire will contribute towards, insofar as is reasonable and sustainable, the unmet needs of Greater Birmingham and the overall spatial strategy for doing so. Cala supports the inclusion of LMA within the indicative list of settlements and locations that can facilitate the initial growth options, recognising that LMA is an important strategic site that will deliver a significant quantum of housing across the plan period. It should be retained as an allocation and included as a location for future housing delivery across any and all chosen growth options within the SWLP. Further, any growth option should actively support LMAs delivery (as a key brownfield site and location that will eventually become one of the largest settlements in Stratford District) in respect of its approach to growth in the wider Stratford area.

The parcel of land at Bush Heath Lane is approximately 1.09ha in size and located directly adjacent to the settlement boundary of the village of Harbury. This site has previously been assessed within the SHLAA both in 2020 and in 2021, but the site was not put forward by the joint owners. Both times there were a number of criteria which were flagged as ‘red’ (red, amber, green being the suitability of the site/or meeting the criteria). These were down to the following issues/criteria: • Relationship to highway • Intensions/ownership • Landscape Impact • Landscape Sensitivity These red flags applied to most of the sites which were located as part of the Harbury and Deppers Bridge Neighbourhood Plan. The site is now submitted with the support of a Transport Technical Note which looks at potential access locations as well as traffic data etc which deals with the relationship with the highway given that the Bush Heath Lane already has residential development along it. This note concludes that the residential use of the site can be accommodated within the existing local highway network, as well as a new access point along Bush Heath Lane .This conclusion also takes into account any highways safety issues the new access would have together with the previously proposed access for the site opposite. We are aware that Gladman Ltd submitted a hybrid application for the site opposite in 2019 for: full planning permission for the change of use of agricultural land to cemetery with vehicular access from Temple End; and Outline planning permission for the erection of up to 120 dwellings and associated infrastructure with all matters reserved except for access. This application was withdrawn on 26th February 2021. We note that this site has been submitted as part of the first Call for Sites consultation in 2021, as site for mixed use development. A Preliminary Ecological Appraisal was undertaken to understand any constraints that may have been present on the site. This assessment is submitted in support of the Call for Sites as part of the technical information to help assess the site. The site predominantly comprises of arable cropland, hedgerows and scattered trees. The site also has some potential to support bats, birds, amphibians and terrestrial mammals. It would not be unusual for undeveloped site to have potential, however it would need to further assessed through surveys as to what this potential is as well as detailed mitigation for any proposed development in the future. The Site is available for development, and has the full support of both joint owners. With regards to landscape sensitivity and impact, the Site is not located within the Green Belt but is located in the Open Countryside. The adopted Neighbourhood Plan covers the same period as the current Core Strategy so up to 2031, so upon adoption of the SWLP the neighbourhood plan would need to be updated as it would be considered out of date. The current built boundary is tightly drawn around the village where there is existing development or where at the time of writing planning consents were granted. Whilst there is a policy of allowing residential development, this is within the boundary of the village. Site 1 is located to the south of the residential development of 27 dwellings which had reserved matters approved in 2012 along Bush Heath Lane and Ridgley Way and the other modern development along Bush Heath Lane. The site put forward would be located partly opposite the site which had its application withdrawn, but would seek to provide a modest number of units directly adjacent to the current boundary of the existing village settlement. This would seek to mirror the existing densities which are located adjacent to the site and follow a similar layout to development but ensure that there was more of an emphasis on green space and ecological enhancements as part of the site’s function.

Ashow is a beautiful, unspoilt, very small village which deservedly enjoys the protection of being in the green belt. There need to be exceptional circumstances to justify building on green belt and none have been presented. The plot of land in question sits outside of the village boundaries, so does not qualify for infill consideration, and is in a conservation area that the council itself has identified (Ashow Conservation Area report) is especially important to preserve the character of. There is no mains drainage in Ashow and there are only 2 roads - one of which is very narrow, steep road with no space for a pedestrian footpath or street lighting and with no turning circle at the end which cause congestion and difficulties turning already, particularly for deliveries / oil tankers / horse and sheep trailers etc. A Paper was prepared to support the proposals for housing allocations in villages, as set out in the 2016 Local Plan Modifications. This work analysed each of the main rural settlements in the district according to their current population and settlement size, service availability and accessibility. This was used to identify those villages which provide the most sustainable locations which can support, and potentially benefit from, some development. Specifically this analysis generated a score for each settlement which allowed villages to be classified in the Local Plan as follows: The highest score was Hampton Magna with 57, and, more locally, Leek Wootton with 38, Stoneleigh with 25, and Ashow with a minimum score with Blackdown of 16. (1) I request that the proposed development of 10 houses offered to the Council in Ashow is not accepted as part of the go forward Housing Plan following the Council's request for land to be identified for housing or other uses. The site identified is outside the "Village Envelope" and any infill development needs to be within the village boundary and should be based upon housing needs. We have 2 houses in the village currently for sale that have not been sold despite being on the market for over 6 months, so there is not any genuine housing need and we should not have to continually defend planning applications for it going forward which will be costly for the local authority and probably a waste of taxpayer's money when the site is properly assessed totally unsuitable. (2) I request that the development of light industrial units opposite Dial House Farm is not accepted as part of the go forward Housing Plan following the Council's request for land to be identified for housing or other uses. There is no one unemployed in Ashow village that requires employment. Also any development generally out of Leamington towards Kenilworth means that the countryside and green belt between the towns will be lost. It will end up like Leamington - Warwick where there is no green boundary now at all between the towns. We live in the countryside but there are fewer and fewer areas for rural activities - horse riding / basics such as walking the dog through pleasant countryside which was so important for everyone's mental health during Covid. People living in Kenilworth and Leamington town centres love to walk to our village as it is a pleasant country walk within easy reach to them – and accessible without need of a car, with a lovely village club open to serve tea etc half way.

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. The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.

The allocations of housing are at best questionable. For example the allocation for Wootton Wawen of up to five-hundred houses in a small village with an existing population of 2000 is completely unacceptable. It is founded on questionable logic and flawed assumptions. In particular, Wootton Wawen is one of a number of areas close to railway stations where a disproportionate number of houses have been allocated.

I do not agree that the Green Belt boundary should be amended in order to develop for housing because I do not see why it is necessary for Warwickshire to house overspill from Coventry and wider west Midlands conurbation on important amenity. The Green Belt around North Leamington is a valued open space. In surveys residents say that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health. It is easily accessible on foot from North Leamington so many people can access the public rights of way across the fields. Use of these footpaths increased markedly during lockdown and these high levels of use continue today. The agricultural land continues to provide rural employment and undergo diversification of farming techniques. Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever. The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. Recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The land making up these sites is, therefore, considered to be a scarce resource of high value for sustainable food production. The Government seeks to protect against the loss of such land from non-agricultural development. The National Planning Policy Framework is clear that “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality”; a policy which will continue to grow in significance as the increasing cost of imported wheat and grain drives up domestic food production needs. The proposal to move Green Belt boundaries would lead to a merging of the boundaries of Kenilworth and Leamington. Developing the North Leamington Green Belt would significantly reduce the belt of land that separates Kenilworth from Leamington, particularly in view of the Thickthorn housing development now underway and other recent housing and commercial developments in the area. The proximity of HS2 developments in neighbouring parishes is also strongly felt. Despite this, numerous other sites along the A452 have been put forward in the Call for Sites. Once land is removed from the Green Belt for development this cannot be undone and a precedent is set which makes it easier for adjoining swathes of land to be built on. Building more new houses on the outskirts of Leamington will exacerbate the current high levels of traffic congestion which has come with the new housing developments south of the town. The original layout of the town and the subsequent development in the 19th and 20th centuries precludes the construction of major new cross town access routes. The joint Green Belt study of 2015 highlights the important contribution to preventing the merging of Leamington, Kenilworth and Coventry that this piece of the countryside (Broad Area 3) makes by preventing urban sprawl, safeguarding the countryside and preserving the special character of these historic towns. Similar proposals to move Green Belt boundaries 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. Giving up Green Belt and moving boundaries 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” . The utility of the Green Belt around North Leamington is a genuine constraint on development. Moving the Green Belt boundaries It skews development away from affordable housing in the areas where people work. The Government has also made a “brownfield first” pledge (see letter above) which should inform the way that the District Councils respond to unmet housing need in other authorities. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit. The process is flawed because all five options presume Green Belt development without acknowledging the significant constraints involved. The Issues and Options consultation puts forward five “spatial growth options”. All of these would involve development of some areas of Warwickshire’s Green Belt, and all of them suggest North Leamington Green Belt as an area of ‘significant urban extension’. This is in line with the outcomes from a series of spatial growth workshops which revealed a preference to promote development at scale within the Green Belt. However the premise of these workshops is grossly flawed. The proposition that Green Belt serves no legitimate function and can be ‘switched off’ as an academic exercise flies in the face of the significant contributions that Warwick District Council and Stratford District Council have themselves noted that Green Belt designation makes. The Green Belt puts major restrictions – for good reason – on what can be built where. The spatial growth workshops did explore growth options where Green Belt development was not permitted. However none of these feature in the current five spatial growth options. This is contrary to recent Government announcements, the 2015 greenbelt review and the 2017 response by the Planning Inspector. The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. We think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development.

I am specifically opposed to development of land in the greenbelt areas around Hunningham 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.

Please do not build anything on our green belt/green spaces. This development must stop. We must start protecting our landscape and habitats. Surely this needs revisiting.

The premise of the plan is flawed because Green Belt growth is assumed while the case for it has not been made. Options should be presented which seek to avoid or minimise Green Belt development, in line with the non-Green Belt options explored in the spatial growth workshops carried out last summer. This would bring the SWLP into line with current national policy and would also better support the Plan's own strategic objectives. The Secretary of State has stressed the need for local authorities to work with their local communities "to determine how many homes should actually be built". The local community around North Leamington do not want the Green Belt to be built on. This area is hugely valued for many reasons already outlined in my response, for example (i) It is high quality agricultural land which should be safeguarded in view of national food security issues. (ii) Its footpaths offer recreational and health benefits for many people in the town of Leamington Spa who can access the area on foot. The number of people accessing the footpaths increased hugely during periods of lockdown and this usage has continued since. (iii) It prevents a sprawling northwards of the town of Leamington Spa and forms a green ‘northern gateway’ to the town. This in turn helps to maintain its setting and special character. (iv) It helps to maintain the distinct identities of the towns of Kenilworth and Leamington Spa and prevents them merging into one another. (v) It assists in urban regeneration, by encouraging the recycling of derelict and other urban land, in line with the Government’s “Brownfield First” pledge. In short, the Green Belt in North Leamington meets all five purposes of Green Belt land. The Planning Inspectorate validated this position only six years ago when development proposals were last put forward and then rejected. One of the aims of the revised NPPF is to prevent Green Belt land being developed to meet a housing target and the SWLP team should therefore reconsider its proposals in the light of this.

Green belt should be left untouched

Please do not build anything on our green belt/green spaces. This development must stop. We must start protecting our landscape and habitats. Surely this needs revisiting.

There are several errors in the consultation document, particularly appendix 2 section C2, pertaining to Bearley. When these are taken into account Bearley is not suitable for inclusion in any of the 5 main options and will not add to any Sustainability targets. • The recently planted Heart of England Bearley Community woodland is not shown in figure C.2.1 of the Sustainability Reports Appendices. This should not be included within the potential small settlement boundary • Bearley Village Hall and Sports field should not be included within the potential small settlement boundary • No school • No shops • Minimal street lighting, especially between the village heart and the transport links. • No GP surgery • Very little existing local employment and no potential new employment • Poor Bus and rail communications o The railway halt is on the Stratford to Leamington line and has no direct access to the Stratford to Birmingham line. There are no direct commuter trains to Birmingham or Warwick, and no direct trains to London. There are no station facilities (waiting room or toilets) and no car park. o The railway halt and bus link north are on the opposite side of a very busy road (where there have been fatalities) from the village . o The bus service has no direct access to Birmingham, Leamington, Warwick, or Coventry and to get to the nearest A & E at Warwick Hospital needs 3 buses and a minimum of 1.5 hours (2 to 3 hours more likely, with a risk of not being able to get back due to NHS A & E waiting times). • There are several housing developments in progress or under consideration in Bearley. Any further development into the Green Belt will result in the loss of productive agricultural land. • Any housing development in Bearley will add typically 2 cars per household for work and school transport, with consequent increases in emissions and congestion Answering Specific Questions Q-S7.2 Option 1: Rail Corridors This option is not appropriate to Bearley. Whilst Bearley has a railway halt, its on the Stratford upon Avon to Leamington line, not the Birmingham line. Currently there are very few trains each day that stop in Bearley (and some of these are 'request' stops). There are no direct commuter trains to Birmingham, Coventry, Leamington or Warwick. There are no direct trains to London. There are no passenger facilities at the station (no waiting room or toilets) and no car park Consequently the station is not used very much. So any new householders are unlikely to use the train and will need multiple cars for work and school transport related travel with the associated increases in emissions and road congestion. Option 2: Sustainable Travel This option is not appropriate to Bearley. Bearley has a minimal bus service, and no direct service to Birmingham, Leamington, Warwick or Coventry. Journey time where a change of bus or bus to train will not be attractive. Hence any new household will need multiple cars for work and school transport related travel with the associated increases in emissions and road congestion. . Option 3: Economy This option is not appropriate to Bearley. There are very few existing work opportunities within the village or it's surroundings. Option 4: Sustainable Travel and Economy This option is not appropriate to Bearley. Bearley is an essentially rural village surrounded by arable land and woodland. Its why people live here. Any significant change would cause many people to move. Option 5: Dispersed This option is not appropriate to Bearley. Bearley is an essentially rural village. It lacks facilities and work opportunities. It has NO shop, school, minimal street lighting, post office, medical facilities, bus connectivity, or convenient train service. Also by building on it's surrounding green belt, this rural nature would be eroded, and after all, that's why most of it's inhabitants choose to live here. Why not consider Bearley Airfield rather than consuming arable land in the Green Belt. Additional Points 1) I take issue with 54% of stage 1 respondents being positive. A large number of these were Developers. Most people in Bearley were not aware of the consultation. Your document refers to an 'A4 flyer' that was sent by Royal Mail to a large number of households. We did NOT receive one. I only found out about stage 2 yesterday (March 3). Has there been a communication breakdown ? 2) I would question the use of ONS 2014 data to drive the required number of new houses needed. This was before Brexit and COVID which has changed the situation. Also I know there are a lot of immigrants needing houses, but they need education and jobs in order to afford houses. 3) Bearley expended a huge amount of effort to produce its approved Neighbourhood Development Plan. I am deeply concerned to see no consideration to this. 4) The report indicates the use of electric vehicles as a panacea to emissions problems. The facts are a little different. • The manufacturing process for an electric vehicle generates more CO2 than for a petrol / diesel engine vehicle (see VW study 9.2 tonnes / 7.2 tones) • Whilst 'in life' emissions are lower with an electric vehicle, they are not 0. Typically they are 70 to 83 % of a petrol / diesel engine vehicle (European Energy Agency research). • Vehicle batteries contain many toxic and difficult to process materials that need to be disposed of at their end of life

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.

The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity. Any new development is an opportunity to create a paradise with gardens, allotments, fruit trees and sustainable buildings that supplement nature, encouraging healthy and happy living but instead we get developer designed, outdated, environmentally damaging and soul destroying identikit mass-housing creating blots on the landscape over and over again. When will we learn?

Please find below a response submitted for and on behalf of the Kenilworth History and Archaeology Society in respect of one particular site which has historic significance: Site details: LP 12Nov21 Camp Farm REFID 32 DISTRICT WDC SITENAME Camp Farm ADDRESS Hollis Lane, Kenilworth, 2JY Introduction The Camp Farm site comprises three fields separated by two hedge field boundaries. The eastern field is a remnant of the historic 'Pease-Croft' field and the central and western fields are remnants of the historic 'Hinewelle Siche' field. Both have various spellings in historic documents. The eastern field - a part of the historic 'Pease-Croft' field The hedge boundary between the central field and the eastern field preserves a part the boundary of the Pease-Croft' field, since sub divided, which appears on the 1628 Harding, and 1692 James Fish, Castle Estate maps. The line of the external boundary hedge and adjacent drainage ditch along Hollis Lane is also shown on these maps. These boundaries are also described in the 'Parliamentary Survey of Crown and Ecclesiastical land for houses and land of the 'late dissolved monastery within the honour of Kenelworth alias Killingworth" dated 1650, and S.G. Wallsgrove's book 'Kenilworth 1086 - 1756' indicates that the Pease-Croft name and field boundaries date back to the medieval period. The central and westerns fields - a part of the historic 'Hinewelle siche' field and location of the disappeared Conduit House shown on the 1628 Harding map The historic field name 'Hinewelle siche' has two latter elements that are understood, being well + sitch, meaning a ditch or sike, however the first element is uncertain. It could be that 'Hine' was a personal name, perhaps Huna, which is thought to be the origin of the nearby village of Honiley, according to the English Place Name Society. As the field has the spring and associated stream (now diverted through a buried pipe), the well + sitch in the early field name could indicate that the name dates at least from the time when Old English was being spoken. Within the central field, a disappeared feature with links to both Kenilworth Castle and the priory has been considered to be of sufficient importance to warrant an appendix in the 2017 English Heritage book 'The Archaeology of Kenilworth Castle's Elizabethan Garden - Excavation and Investigation 2004 - 2008'. This appendix identifies a Cundit (Conduit House which channels a spring water source into a pipe) marked on the 1628 Harding map as the likely source of the water that fed Robert Dudley's fountain, built to impress Queen Elizabeth I on her visit to Kenilworth Castle. Such Conduit Houses are usually associated with monasteries and it is unlikely to be coincidence that Dudley had acquired the castle and the adjacent dissolved priory and former monastic lands. A new entry for this feature has recently been added to the Warwickshire Historic Environment Record (HER). The route of the presumed lead pipe connecting the two is not known, likewise the location of a 'lane across the fields' shown on the 1692 map. The hedge separating the western field and the central field appears to be post enclosure, so is not considered to have historic interest. Given the history associated with the above features, it is worrying to see that it may be developed as a housing estate. If it is to be developed, please will consideration be given to making an archaeological examination of the spring and investigation of heritage potential? Drainage challenges The area within and to north of the Camp Farm plot appears to have active springs and land drains, and all the fields have slopes. Pease-Crofts Rain falling onto the Pease-Croft field, together with water from springs and/or land drains, goes into the Hollis Lane ditch, which is rarely completely dry, even in summer. Taking advantage of the ground water in this area, just to the south of the eastern field, is a Severn Trent water abstraction facility. The ditch on the Pease-Croft eastern boundary (Hollis Lane) carries water south alongside the lane towards the junction with Beehive Hill, where it disappears into the ground into underground infrastructure that neither Severn Trent or WCC appears to have records of. The Harding map indicates that in 1628, from this point, a continuation of the Hollis Lane ditch ran across then open ground in a ditch following the line of the shallow valley heading toward the ford at Finham Brook in Abbey Fields. With the development of housing on much of its route, many sections of the former ditch have been replaced with Severn Trent underground water drain pipes, but some remnant sections of the 1628 ditches, now in the rear gardens of a number of houses on Amherst Road remain. Another ditch, possibly in a diverted position, runs alongside the Clarendon Arms. As for the section now believed to flow under Beehive Hill, historic newspapers indicate that a new culvert was constructed as a part of a council road widening scheme along with new kerbing in 1921. A 1911 newspaper described a blockage in a culvert immediately downstream of it. When asked, Severn Trent and WCC responded that they have no records of any such culverts. The 'Hollis Lane to Finham Brook' water course is unusual in that in the summer it dries up almost completely, but after heavy rain it has a strong flow and can cause localised flooding. The most problematic areas are the road above the presumed culvert under Beehive Hill and the ditches mentioned above. Hinewelle Siche Water from the west slope runs towards the A452 and appears to go under the road to a culverted section of Finham Brook running parallel to the A452. The English Heritage book describes the now disappeared stream that ran from the Conduit House to the A452 and the land drain that replaced it. The culverted section of Finham Brook is understood to be the responsibility of Warwickshire County Council (WCC). Sources/Further reading/References 'Kenilworth 1086 - 1756" S.G.Wallsgrove 1991 Warwick Printing Co. Chapter 3. '[the Abbey] Confirmations and the early 13th Century" The plot forming the site is shown on Fig. 4 '12th and 13th Century features' as being part of the field then known as 'Hinewellesiche' Chapter 6. 'The Dissolution' Figure 7 shows the 'Hennelsiche' Chapter 9. 'A Changing Society' Figure 10 'Common Lands + Fields Enclosed 1756' shows the Pease-Croft western boundary, with the land to the west identified as part of the enclosed Prior's Field Chapter 11. 'The Odibournes' Figure 12 'The Odibournes Based on the 1628 Map' shows the Hollis Lane boundary with the southern 'Pease-croft' field National Archives Harding Estate Map 1628 This map, cited and reproduced in part in S.G. Wallsgrove Chapter 11, Figure 12, shows two lines marking the Hollis Lane ditches which exist today. The map shows the northern section of the original route that the water took, via what appears to be a man-made ditch, due to its straightness, in its journey to Finham Brook (see Lidar below). This map also shows the Cundit [Conduit] House described in the English Heritage book and a related Historic Environment Record. Warwickshire County Record Office documents Parliamentary Survey of Crown and Ecclesiastical land for houses and land of the 'late dissolved monastery within the honour of Kenelworth alias Killingworth' 1650 ref: CR 5162 This identifies the 'Paes Croft' field west of Hollis Lane, with Prior's Field to the south and west, as being former monastic land. The area of the plot is recorded as 41:02:24 Kenilworth Castle Estate Map by James Fish 1692 ref CR 143A Kenilworth Castle Estate Survey 1692 by James Fish ref. CR 0143/1 Kenilworth Castle Estate Survey 1722 by James Fish ref. CR 311/36 Ordnance Survey maps Some early maps show a water course from the site of the disappeared Conduit House to Birmingham Road/Finham Brook. English Heritage book 'The Archaeology of Kenilworth Castle's Elizabethan Garden - Excavation and Investigation 2004 - 2008' 2017 Brian Dix, Stephen Parry and Claire Finn, English Heritage Appendix 2 'The water supply to Leicester's Fountain' has a modern os map of the fields, showing the location of the 'Cundit House' shown on the 1628 Harding Estate Map, along with a reproduction of the section of that map, plus modern photographs and narrative. Warwickshire Historic Environment Record (HER) Warwickshire County Council have recently updated the HER to add a Monument for the Conduit head/ water supply to Leicester's Fountain. For reference this is MWA32462. It may not be on the Online version of the HER yet, but will be included in any data sent out for HER searches, and available to be viewed on the HER. Lidar data Identifies the natural valley, that before the area was built up and drains laid, took the surface water from the fields adjacent to Hollis Lane, and around the area within the valley, to Finham Brook Warwick Council website Flood Map Flood evidence along the Lidar valley route. Newspaper Articles Leamington Spa Courier - Friday 13 January 1911: blockage to culvert under land south of Beehive Hill. Leamington Spa Courier - Friday 17 June 1921: new culvert across the road, and kerbing round Fieldgate House

My main comment is that the Green Belt should be protected at all costs, we have lost enough already with HS2 we don’t want to be losing any more.