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

I have written several letters to input ideas into the local plans , however I'm moved to write again , Regarding inclusions what I feel should be important inputs . into the local plan at east Whitnash , I feel strongly that forsight is lacking amongst local councillors . There seems to be reluctance to move away from emotionally held views that links between Whitnash proper and east Whitnash should not be considered , It's a kind of stuck in the mud attitude , The issue is access for residents living in east Whitnash is desperately needed, it's as though they are a forsaken lost cause ,not to be addressed. for the sake of some councillors wanting to hold onto Thier own memories and not wanting change. But this is not for them , it's for their grand children , it's the future ,and the future means change , The road known as Church lane leads from Whitnash road via a narrow bridge that crosses the rail line , and then follows an old farm track that was used by famers , although it's classed I'm told as a bridle way.18th century !!! Which I feel should lose that status to allow progress to move forward into this century , church lane would be a really practical route to service the area , the Bridge could be easily widened to carry heavier traffic , the bridle road which is tarmac surfaced could also be widened it's full length , to creat a loop road for vehicles ,cyclists ,walkers and give good acces for emergency services , Planning was recently granted ,via expensive appeal for the first tranch of 200 homes at East Whitnash with three hundred to follow , and then later on further down to use lands heading south already in the local plan towards the fossway , surely a road direct to the fossway is far more sensible creating a new access road from which could be constructed as already mentioned Park and ride service to London , It's an area that would suit homes without industry to spoil it's outlook

I have become aware of the proposal to allow change of use for Bridge Farm and Bridge Barn Farm from agricultural to mixed use and your consultation on the SWLP in general. The farms are situated between Hunningham and Weston under Wetherley. I would like to object to any change of use based on this causing: • Depletion of the limited stock of farms for new starters - they are council owned and rented • Removal of two farming families livelihood • A reduction in Warwickshire County Council’s ability to perform carbon offsetting • A reduction in ability to be more self-sufficient with food production • Part of the land is a floodplain so not suitable for most development. • Mixed development would entail more impermeable surfaces and increase run off and hence flood risk • The inevitable removal of hedges and trees will also exacerbate flood risk • The current level of flooding already at times affects the use of the bridge at Hunningham and the ability for the pub to be open. It is possible more frequent and higher floods may damage the medieval bridge • My understanding is the brewery’s decision to sell the pub several years ago was heavily influenced by issues with closure to itself and the bridge. It is currently run independently and attracts custom and money locally and out of the area. The customers also enjoy the local countryside. It would be a shame to risk a rural pub further especially after the financial impact of Covid. The pub in Weston has already been changed to residential • The narrow roads leading to this area would struggle to take a big development and there is currently a lack of infrastructure to support it. • There are more appropriate areas, with better access and closer proximity to towns for mixed development reducing the need for car journeys into the countryside which are better from a climate emergency prospective. • The footpaths across these farms are frequently used for countryside recreation and access to the bus routes in Weston. There is no footpath/pavement along the road linking the two villages. • The valley has already been developed by HS2 and further development will affect the wildlife, biodiversity and unique nature of the villages of Hunningham and Weston under Wetherley. This current farmland is open space much enjoyed by many, both by accessing its footpaths and enjoying its vista

Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in Green Belt areas. The plan should not allow for more small-scale growth developments to come forward in Green Belt areas. Any other comments: I am specifically opposed to development of land to the North Leamington Greenbelt and areas such as Old Milverton, Weston under Wetherley and other similar small Green Belt villages due to the impact on the rural character of the area and the implicit urban sprawl. 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 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 than they were in 2017. The Climate Emergency is not a justification to develop on Green Belt 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. The statistics in Chapter 4, issue S6 are misleading. The number of respondents (561 responses) to the first consultation was exceptionally small and can in no way be considered representative of the population area. Most people felt the previous consultation was aimed at site owners and did not respond, which explains the low response rate. This issue should not have been included within the consultation without the option to comment. Your statistics are entirely misleading stating 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, 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. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). The letter from the Secretary of State Secretary of State in December 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. I am also is concerned 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

I would like to comment on the SWLP, in particular with respect to the area earmarked for development ref_id 569 (Weston under Wetherley South) - but my comments will apply similarly to other "free standing" greenbelt areas. The idea to set up large new settlements within the greenbelt / countryside brings along a number of issues that, in my view, should be avoided. * traffic: whereas some local amenities may be created alongside ('a la "Tesco Express") it is likely that most inhabitants of the new settlement will drive to the bigger shopping areas in the urban centres.For the Leamington area, that is Leamington itself, and Thatchbrook Park. Equally, almost everybody within this new settlement will commute to work by car, as public transport is very limited / non-existent. Even if a local bus will be set up that takes people into Leamington, it is not appealing in terms of commute time. Local roads from the planned settlement between Weston under Wetherley and Hunningham are already busy (Rugby Road & Fosse way). Thus, areas that extend existing urban areas would appear more suited, ideally focusing on the M40 corridor. I am aware that train stations play a role in the planning, however, given the track record of the train services, and capacity limits on the existing lines (where HS2 will do nothing to alleviate those), most people will continue to travel by car. * HS2 is already having a significant impact on this area, with ongoing construction work over years continuously disrupting everyday life. As such, it would be good to "spread the pain" and avoid additional long-term disruptions for the local population who endure the stress of HS2 works. * at least part of the earmarked area is subject to flooding, building on flood zones should generally be avoided.

The thought of Henley coping with a doubling of the population is ridiculous and this is what we are being threatened with. An increase of up to 2000 homes which has been mentioned would mean the population rises from approximately 3,500 to 6,500. It seems that the decision for this massive increase in the footprint and population of the town is based on its amenities which is a fallacy as anybody that knows Henley would tell outsiders. - The NHS facilities (Medical Centre and Pharmacy) are overwhelmed - We have a High Street which consists mainly of hairdressers, estate agents and pub/restaurants. No banks or building societies. A post office which is often not open for days at a time. - A bus service which is regularly threatened with closure which only goes from North to South. Nothing to go East/West where hospitals and jobs are. - A train service which runs when it feels like it or when there is a driver and a railway station which is being turned into a microbrewery. - Schools which are at near capacity and certainly couldn't cope with up to more than a thousand extra pupils which would be the case. - Car park capacity is totally unable to cope with the current population let alone doubling of the population - Seven years ago we were told that our sewerage system was at capacity. - We are reasonably close to the Motorway network but the impact of motorway closures on our road system is awful. In conclusion the most obvious crime of this plan is the total vandalism of a beautiful 11th century town which encompasses the history of our country within its perimeter. There is no way this can be protected from the effects of turning Henley into a 21st century new town.

Our family has lived in this area for well over 20 years and have the following objections to extensive housing development here for the following reasons. 1.The country lanes are totally unsuitable to increased traffic, our lane is one car wide for its entire length with occasional passing places. Crashes are inevitable and there is no scope for widening. Expanding on this potential danger, the small field close to the Warwickshire Lad is on a severe slope and access to Broad Lane via Wood End Lane is an inevitable crash hazard. 2.Many houses have limited services already.We have no gas supply,no mains sewage and have had to install electric pumps to facilitate sufficient water pressure for showers. 3. Flooding. All fields close to Spring Brook flood. This has happened already in January 2023. The heavy clay soil is impossible to drain. 4.Environmental Damage. Being in the Forest of Arden encourages the wild life. More building would seriously endanger the deer, birds and other small mammals.In conjunction with the Wild Life Trust,we have been planting hedgerows to encourage particularly the dormice which are endangered. This has been successful and several nests have been seen last year in the new hedges. Greater crested newts are also suspected to be here. 5.Noise. Many of the fields on’ the call for sites map ‘are precariously close to the Motorway where noise can be intrusive and harmful to health.I gather when the motorway was first built compensation was given to many house holders! To expand on noise, any tree felling,an inevitable sequel to house building,will inevitably increase the noise, these is even particularly noticeable in Winter when the deciduous tress have lost their leaves. 6.Parking.There is no parking at Wood End Station and very limited at Earlswood. 7.Loss of Green Belt. With the already probably inevitable construction of Fulford Green by Solihull, any further building in the Wood End ,Earlswood areas would create an extensive housing mass with detriment to the people and the animals and environment which we are supposedly attempting to protect.

Wawensmere Road – a country lane, single track from Brickyard Hill to Chesters Green crossroads then Chesters Green/Hardwick Lane crossroads to A4189. • Speed 60 mph - very dangerous - but from Mappleborough Green to Henley-in-Arden A4189 - 50 mph (new signs been put up in 2022 with speed limit) • Used as a rat run! ( 8.30 am 9 Feb 2023 –( a tractor pulled over and 30 vehicles passed him) • Should have a weight constriction to non agricultural vehicles – no construction vehicles • This road is popular to cyclists, inter link to various footpaths and bridleways , walkers and horse riders -all used daily. Land under Wootton Wawen rail bridge on left from village • This piece of agriculture land has a purpose - • if it was built on the resulting driveways and hard standing, would not be able to cope with the run off from the rain , therefore causing local flooding which already is a problem in this area. • Flooding of B4089 by the school and pub would happen regularly. • Railway bridge – very narrow , blind spot especially when cars parked on road under the bridge • Junction Wawensmere Road at Toll House B4089 – people pull out from Alcester Road because they can not see up Wawensmere Road, under railway bridge. ( Often due to cars parked) • Also blind if coming down the hill when the sun is low. • • Gorse Lane – narrow lane , houses on junction with Wawensmere Road by railway bridge. • Main access to Wootton Hill Farm Harvest time would be a nightmare! As farmers, many use the grain store at Pools Farm, Little Alne, This is a large agricultural contractor, one of many farmers, with large grain drying and storage facilities, Environmental impact Each time a new human habit is made, the wildlife habit is destroyed and the resident wild life made homeless. HS2 environmental report – they have got it wrong and can never be restored. . Deer – there is such a huge problem with deer, particularly fallow ( to large to poach , put in your car and butcher on the kitchen table) The deer are still breeding at the same rate , but less area to live (sounds like other countries – elephants, lions ect) To keep the numbers static we need to cull 30% of the deer locally. The Forestry Commission are very concern – so much so a new committee is being set up to find ways of culling deer and putting in the food chain – wild venison. Wait for complaints about deer eating all those delicious roses! Badgers – protected, we have a healthy population and badgers love space and foraging . ( Adjacent land to Four Posts – as you are aware have filled in a badger set, badgers have a summer and winter residence) Hegde hogs- use to be a healthy population on Brickyard Hill Trees – Heart of England would be interested in planting trees in these areas to extend the 30,000 acre forestry project in the area. There are TPO’s – Tree Preservation Orders in the area. Bird habitat Wild flowers and fauna Farms are now encouraged to take land out of food production and grow wild flower mixes, bird mixes to help the wildlife which will enable them to survive the ever increasing human impact. Wootton Wawen would need a medical centre, pharmacy , school, recreational facilities, telephone exchange – improved internet access, dedicated police and emergency response teams. Unfortunately, the human population has exploded and so many do not understand the fragile environment we live in, everything has to be fast and disposable. These are my thoughts on Stage 2

I am in favour of housing development of circa 150 houses ( the suggested allocation being 500 ). Wootton Wawen would benefit from more housing My suggested location for new housing would be around the rear of the school off The Alcester Road which is also close to the railway station A S106 could be utilised to create sufficient parking close by

I do want to specifically address the proposals to build on the Green Belt to the north of Leamington Spa. I suspect this is well documented already and also suspect that a great number of similar views have already been expressed. But I believe it is wholly inappropriate to develop on the green belt to the north of the town: 1) Green belt designations were applied to prevent urban sprawl and the character of the countryside (including the built environment therein - i.e. villages) being eroded. What is being considered, is exactly the opposite and would see a number of villages completely absorbed into the town, and the loss of the green area between Leamington and Kenilworth. The entire point often green belt is to prevent exactly what is being proposed. 2) Huge numbers of houses have already been built to the South of Leamington (and effectively join Leamington and Warwick), and whilst there is clearly a huge demand for more houses throughout the UK, eroding yet more green spaces between towns seems to be completely the wrong answer. Is it really appropriate to merge Leamington with Warwick, as has already been done to the South, and now to merge Leamington with Kenilworth? Again, this urban sprawl seems to be precisely what the green belt designation is there to prevent. 3) The majority of housing being built in the area seems to be bigger/luxury type housing which perhaps isn’t always what is actually needed (although they do all seem to be selling!). Surely building greater number of homes (perhaps smaller homes) on brownfield sites would be better - perhaps on the town centre car parks (by way of example, it must be possible to redevelop Covent Garden and Chandos street car parks to provide greater numbers of parking spaces and residential/other uses - and there must be other brownfield sites too)? 4) The Green Belt to the north of Leamington provides recreational facilities for large numbers of people which would surely be lost if the area is built on. 5) Has the quality of the farmland that would be lost, been assessed? Food security is hugely important and keeping the best farmland must surely be a priority. 6) Weren’t proposals for building on this area rejected by an independent inspector relatively recently? If so, why try again. Whilst there is clearly a demand for more housing, this doesn’t seem to be the preferred option (by locals, or by an independent inspector). 7) I think this proposal is at odds with government policy on green belt designations. I believe I saw comment in the property press in December last year, to the effect that central government is NOT requiring LPA’s to review green belt designations simply to meet housing demand figures (which I seem to recall are also not now seen as anything other than a starting point). In summary, whilst I suspect a great number of these points have already been made by others, it seems wholly inappropriate to remove the green belt designation to the north of leamington, unnecessary, contrary to central government ‘rules’, and unwanted.

we wish to comment on the development proposals near Old Milverton and through to Kenilworth. These fields and countryside currently form a vital open space around Warwick and Leamington and further development would seriously reduced this amenity . In any case this whole issue was settled only six years ago and should not now be reopened. This type of green belt erosion should and is completely unjustified.

I understand the land either side of Leicester Lane in CV32, north Leamington, is being considered for development of housing. This is as part of the South Warwickshire Local Plan (SWLP). I would like to register my strong opposition for any proposed development of this land. I have attempted to do this using the online form but was unable to do so. Any new areas of housing would cause significant traffic / parking problems in and around Leicester Lane, particularly around rush hour times and when children are going into and coming out of school. This would also cause increased pollution for local residents and for the local schools, as well as heightened risk of road traffic accidents involving children and their parents at North Leamington School, Telford School, etc. There would also be a negative impact on nature, particularly around the bridleway between Leicester Lane and Westhill Road; this is currently used extensively by dog walkers, runners and families to walk and is a haven for nature, including the nearby horses that are kept in adjoining land.

Proposals for potential future development Old Milverton & Blackdown Whilst acknowledging the need for future housing in areas such as Leamington Kenilworth & Warwick I find it illogical & irrational to consider potential building on such a scale this side of Leamington. The vast areas of new housing estates on the south side of the town are surely providing the supply needed at this moment in time. It is my understanding that there is over supply & potential excess to market demand. There is a danger of villages & towns merging. For future generations this would be a crime. Adequate rural settings surrounding towns are essential & should be sacrosanct for peoples day to day well being. There are brown field sites & infill areas that surely must be developed as a priority to keep alive our inner towns & villages but not unnecessarily expanded in all directions. Whilst having no objection to small developments by independent & growing developers in this area, ie the Spitfire site at Blackdown & similar it would be catastrophic to cover acres & acres of rural green belt in this area. The comment will surface "not in my back yard" It's not a question of that at all. My husband & myself are elderly. It's caring about our environment & wanting to preserve differential between urban & rural. It has to stop somewhere & I feel legislation on boundaries not being blurred in certain parts of all towns should be legally binding for a certain period of time. I realise that planning applications on these scales are permitted every 5 years but I think the councils need to give themselves some breathing space & address all other important & immediate issues in the community. If there is another way of submitting my views rather than this lengthy letter I'd be happy to concur otherwise please include this in the 'objections' file.

South Warwickshire Local Plan – Housing Development and Sustainable Transport The Draft South Warwickshire Plan sets out several development options, with some involving settlements or developments near or within a certain radius of a rail corridor. If developments are preferred in the final plan close to rail corridors, then the developers should bear the costs of the infrastructure expansion/enhancement indicated as required. The best way for rail to support housing growth in the case of South Warwickshire is to focus new housing around existing stations. Such developments should support the case for enhancements at the stations in question (Shelters, Ticket Buying Facilities and Car Parking). However, we expect an equal focus on delivering dedicated walking and cycle routes from the new developments to these stations. The following would be helpful to promote sustainable travel from the new developments. In terms of providing rail service enhancements to support housing proposals in areas 1 and 2, and 3: 1. Double the frequency of the existing Birmingham – Shirley – Henley – Stratford service from one to two trains per hour. This is essentially an extension of existing Birmingham – Whitlock's End services so no infrastructure is required. 2. Ensure we retain an hourly Birmingham – Solihull – Claverdon – Stratford service for which no infrastructure is required. 3. Seek to deliver a regular hourly Stratford – Claverdon – Warwick – Leamington service and enable through services between Oxford and Stratford upon Avon. This would require investment to redouble the section of railway between Hatton West Junction and Bearley Junction. 4. Seek to deliver a regular hourly Birmingham – Solihull – Lapworth – Hatton – Warwick – Leamington service. The delivery of options 3 and 4 would be significantly helped by track and signalling infrastructure works at Leamington to allow direct access from north to Platform 1 (bay) and may be required if both are pursued in parallel. Funding towards these works should be provided from developers or through mechanisms available to the LPA (Section 106 and/or CIL) The best way for rail to support housing growth in area 4 is to: 6. Increase frequency of hourly Kenilworth service to half hourly (likely to require a complete doubling of Milverton to Gibbet Hill single track section – i.e. more extensive work than currently proposed by Midlands Connect, which recommends Milverton to Kenilworth doubling) 7. Consider the potential new Coventry South / University of Warwick Station. This would require doubling the entire Leamington – Coventry rail line) The reopening of the Stratford upon Avon to Honeybourne railway line should be comprehensively examined, particularly the Total Economic Impact of reopening and the significantly greater level of accessibility and network resilience it could provide, which is crucial with some 391,000 new homes expected to be completed by 2033 across the wider West Midlands. We support a broader vision that includes rail network expansion, electrification, and better train service frequency. Without expansion, electrification and improved frequencies, South Warwickshire will be condemned with a sub-optimal rail network providing a sub-optimal train service leading to sub-optimal environmental, sustainability and customer service outcomes.

As one of the Leamington Milverton District Councillors, 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 and that of many others, 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, 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. Local residents tell us that it is very valuable to them for both their physical and mental health. It is visually of a very high quality and has a number of easily accessible public footpaths across the fields. 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. It is 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 Kenilworth from 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 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 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.

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

New housing to meet local needs will be needed in many settlements but care must be taken in communities like Wellesbourne which over the last twenty years has taken very large amounts of new development that the scale of any new housing has community support and will provide the type of housing that is wanted locally. In all cases infrastructure must be provided before any new houses are built. Green Belt South Warwickshire is sandwiched between the West Midlands green belt to the north and the Area of Outstanding natural Beauty to the South. It has therefore had to take a disproportionately large amount of new development. The non Green Belt areas are also attractive countryside and in places the character of the area is changing quickly with insensitive and poorly landscaped development. If overspill has to be accommodated from Birmingham it may be necessary to create some developmet in the Green Belt. New Settlements Stratford District has already created two huge housing estates in open countryside namely Meon Vale/Long Marston and at Gaydon. The priority should be to ensure that these are properly served and rounded communities. The Plan should never allow such developments to happen again. Planning Enforcement The documents are silent on the enforcement of planning controls. If this plan is to have meaning there needs to be adequate resource given to ensuring that it is adhered to and not abused by developers and property owners. Call for Sites Doing this as part of this process demonstrates that this plan i s developer and not community lead. Any identification of development sites should take place at a later date and needs to have maximum community engagement.

Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced South Warwickshire Councils need a clear policy to protect important environmental assets, designated and non designated sites including potential local wildlife sites. As well as a policy to enhance and restore wildlife sites. Without watering down the policy with wording such as ‘where appropriate’ and in line with the priorities of the Biodiversity Action Plan. The Councils need to plan in line with the legal requirements set out in the National Planning Policy Framework (NPPF), 25 year Environment Plan, the Governments commitment to 30% land in nature recovery by 2030, COP 27 and COP 15 and the Councils declared climate change emergencies. National Planning Policy Framework Paragraph 20d) requires ‘conservation and enhancement of the natural...environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation’ Paragraph 175. Requires Councils ‘take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries’. Q S3.2 Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Brownfield site should be given the upmost priority and areas should only be proven to be an unsustainable location if regeneration projects of the area to make it a sustainable option is not viable.

I am writing to put forward my concerns regarding the proposed planning in place in Henley-In-Arden. I found the online portal quite hard to navigate around so I am writing an email to raise a few issues. Infrastructure Flooding risks as there are at least areas where the proposals are on hills and a high risk flooding area Wildlife - the amount of wildlife that will just be wiped out! What surveys have taken place regarding this? The sheer volume of houses proposed is a massive increase to the area even the lower number is nearly 30% increase on properties let alone cars etc

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. References: 1. Traffic calming: https://www.stratford-herald.com/news/henley-in-arden-to-get-20mph-speed-limit-along-high-street-9280462/ 2. Bus Frequency: Stagecoach timetable 3. Traffic accidents: https://www.crashmap.co.uk/Search 4. Bus Infrastructure: https://www.stratford.gov.uk/doc/206646/name/Adopted%20Stratford%20Area%20Transport%20Strategy.pdf 5. Impact of Traffic on Environment: https://www.stratford.gov.uk/doc/206646/name/Adopted%20Stratford%20Area%20Transport%20Strategy.pdf 7. SFRA: https://www.stratford.gov.uk/planning-building/water-and-flood-risk.cfm

Future Housing plans: Re the future housing proposals, we believe that it makes more sense to create wholly new developments in order to economically create the associated infrastructure that they will require at the time of their inception and also enable infrastructure planning for the future. It makes little sense to us to create moderate numbers of new homes in areas where there is already insufficient infrastructure to support existing housing needs. For example, in the area that we represent, the sewage and drainage system can no longer cope with the additional housing that has been built over the past 20 or so years and there is no apparent appetite on SDC’s behalf to facilitate improvements. When the weather’s dry, the sewage is of sufficiently small quantities that it can be tankered away. When the weather’s wet, the sewage and rain runoff outflows blow the covers off the manholes and flows downhill into the River Blythe, which, as you well know (although choose to forget in the consultation document) is a SSSI. There is little or no parking at the railway stations in the area. Wood End Station has parking for around 6 vehicles, The Lakes Station can possibly accommodate 4 vehicles parked on the road and Earlswood Station has parking for around 12 vehicles. None of these stations has any further land resource that can be used for additional parking. The idea of creating housing along the rail corridor that runs through our area is perhaps convenient for the preparation of a third rate plan but, in reality, will create more issues than it will solve in this particular area. Most residents wish to travel either to Redditch or Solihull and not to Stratford or Birmingham. There is a bus that traverses the route between Redditch and Solihull once per week. The small numbers of rail users using these stations amply demonstrates that neither Birmingham nor Stratford feature as major destinations from this area. There is only one school in the parish and it is heavily oversubscribed. We point this out to evidence the fact that the local communities cannot continue adding housing without substantial improvements to the infrastructure and SDC seems, from past history, unwilling to countenance this expenditure. Therefore, it makes more sense to plan for larger conurbations where the appropriate infrastructure can be incorporated into the plans. Re all the housing figures that are bandied about in the consultation document, where is the evidence that these future population projections are correct? This appears to us to be “the back of a fag packet” calculation and doesn’t seem to take account of the large numbers of those who have passed away over the last couple of years due to Covid. The projected population figures need to be reworked and evidenced independently before meaningful proposals can be considered. The document emphasises the negatives in this future plan. There’s little or no balance in its content. Why not sell it by using the positives instead of asking about the negative effects? Putting forward some coherent proposals as to what you, the professional planners, would like to see and the reasons for those proposals would be a much better approach in our opinion. This should include the positives of each proposal including location benefits and approaches as to how new sites would be developed with the appropriate explanations. We non-professional planners would then have a much better understanding of what’s wanted or proposed. We understand that the largish developments outlined in the current Core Strategy (e.g. Gaydon and Long Marsden) have not produced the numbers of houses that the Core Strategy proposed. As these areas will, presumably, have the infrastructure laid down, these should be the heart of future development for the SDC part of the combined document. Brownfield Land We wholeheartedly support the development of brownfield sites. However, as in the past, we anticipate that SDC/WDC will ignore this asset as the builders will oppose this on costs basis. CPRE has figures that indicate that over 1 million new homes could be built on brownfield sites nationally if local planners had a mind or desire to push in that direction. We ask what happens when we develop so much agricultural land at the expense cleaning up brownfield sites that we cannot feed the population? Ah, with the Government’s current position re agriculture, this is already the case. SDC/WDC should become a beacon in this respect and design a plan that redevelops brownfield sites as a priority. Reference the possibility of SDC/WDC taking some of the Birmingham / Black County housing development shortfall, we would oppose it except and insofar as Brownfield sites were recommissioned for this use. There is a whole Core Strategy’s worth of Brownfield sites in the Birmingham / Black Country are that’s just crying out for redevelopment. Consult with these areas and find out why they won’t insist on redevelopment plans for the area. Green Belt Land You identify land around Earlswood ward and at Wood End as potential sites for development. I was registered to speak at the last Core Strategy inspection and the points that were raised by both our and Tanworth Residents’ Associations re the future development of Green Belt site were sufficiently strong to cause the Inspector to require SDC Planning to go away and rethink this strategy. The Inspector made it absolutely clear to SDC that the Gren Belt was non-negotiable and shouldn’t be meddled with. It’s not obvious to us that this position has altered over the past 10 years. We do not understand why the Green Belt is even being considered as being up for grabs in any future development planning. There’s plenty of non Green Belt land within SDC/WDC’s area of control that can be developed – especially the Brown Field land. Identifying the land around Wood End and up towards Forshaw Heath for a modest sized development has further complications for you to consider. You state in the supporting documents that there are no SSSIs in the area. Either, you have deliberately obfuscated the truth or your research is very poor. The area mentioned above has a number of natural springs that form the source of the River Blythe which is a SSSI for 25 miles due to its clay bed. You will need to take this into consideration when considering your future planning requirements.

Please take notice that I object to the Wootton Wawen housing development plan. The proposal for 400 homes on green belt in a small village is outrageous! The “village “ feel would be gone forever ! The infrastructure is non existent apart from one village shop, two pubs, a train station and school and could NOT support 400 more homes increasing the population by at least 1600 ?! Green belt should be protected at all costs for the sake of a well balanced environment. The village of Wootton Wawen floods during high river tides …. The proposed housing development would add to this issue for many householders .. Preventing water draining away quickly , creating more traffic when roads blocked through flooding .. and more tensions on the village and disrupting present individual flood defence schemes which have been developed by individuals to protect their properties ! It is understood that since writing the plan there has been a shift in the Government’s position. M Gove stated that Green Belt does NOT have to be sacrificed by local plans and should be protected where possible. Consequently there is no longer pressure from the government as there was when the first plans were drawn up! Top down housing figures are often unrealistic … Wootton Wawen’s plan is un realistic and an abuse of the village way of life. Town and city populations benefit from escaping and enjoying the countryside ! It is important that the beautiful English villages are protected for all to enjoy !

Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Growth of existing settlements should be part of the overall strategy. Additional growth adjacent to these settlements offers the opportunity to make efficient use of existing infrastructure, and to make contributions to enhance and improve it for the benefit of new and existing residents. Examples include the expansion of health facilities, increase in bus services, or provision of additional school places or new cycle routes. Allocating land adjacent to existing towns enables new residents to connect to existing rail and bus services, and to access existing employment areas. It does require careful consideration to ensure that new development can be integrated into the existing urban fabric in a way which is not detrimental to existing residents, shops and services. Our client’s site lies to the south-west of Rounds Hill, Kenilworth. It is immediately adjacent to the adopted settlement boundary and to the existing residential development at the south-western edge of Kenilworth Princes Drive employment area, which offers a range of light industrial units and a focus for local employment. As such, an allocation on our client’s site would provide a sustainable location for new development. Issue S6 – A review of Green Belt boundaries As noted in the Plan, the Green Belt includes some of the larger settlements such as Kenilworth, the majority of the railway stations in the South Warwickshire Plan area, and all of the land surrounding Kenilworth. It also covers the northern part of the Plan area, where it would be sensible to allocate sites to meet un-met housing needs from Greater Birmingham and Coventry, due to the proximity of the area to these conurbations. While we acknowledge that the Government’s proposed changes to the National Planning Policy Framework may result in LPA’s no longer being required to release Green Belt land to meet housing need, this should not preclude them from doing so if that is the most sensible option for that authority, and we believe that this is the case in South Warwickshire. A full and detailed assessment of the contribution which land around Kenilworth makes to the five purposes of the Green Belt should be carried out at an appropriately granular level to enable sites to be released. For any growth of Kenilworth to take place, some Green Belt land is likely to need to be released, and therefore this should be accepted proactively by the LPA, and the assessment undertaken positively, with a view to releasing land from the Green Belt around Kenilworth. A balance should be struck between Green Belt protection, and the need to allocate sites which lie in the most sustainable locations. We contend that climate change is now a more pressing and important issue than the retention of Green Belt, and that therefore land should be released from Green Belt adjacent to existing towns if it provides housing and employment in locations which minimise the need to travel, and thereby reduce the attendant carbon emissions. We therefore support the proposal in the Issues and Options document that a comprehensive Green Belt assessment will be undertaken, and will be used to inform the Plan’s spatial strategy, and we look forward to reviewing this document as part of future consultations. Our client’s site currently comprises enclosed paddocks which are located in the Green Belt. In terms of the contribution the site currently makes to the five purposes of the Green Belt, we demonstrate below that its contribution to Green Belt functions is limited: . The site does not check the unrestricted sprawl of urban areas. The site is well enclosed by mature vegetation on all sides and there is further existing built development beyond the site at Hunt Paddocks. . The site does not prevent two urban areas merging into one another. . There is development to the north east, east and slightly further beyond to the south of the site. The site’s current use is enclosed paddocks, not open countryside. Its location, immediately adjacent to built form, and its current use do not assist in safeguarding the countryside from encroachment. . The site does not currently preserve the setting or special character of Kenilworth. This is an urbanized, residential environment with post war residential development in close proximity to the north east. . The allocation of the site would not prevent urban or derelict sites coming forward;

Issue S8 – Small scale development outside of the chosen growth option. 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? A threshold approach could be appropriate, to allow more small-scale developments to come forward. We welcome the acknowledgement in the supporting text to Issue S8 of the importance of small scale development to preserve the vitality of smaller settlements. The Plan also notes that allocating very small sites in a larger number of small settlements may not be appropriate, because it is difficult to predict where and when these needs will arise. We fundamentally disagree with this approach. It should be well understood by the Local Planning Authority which villages have services which are in need of support. Further, Stratford Upon Avon District Council publishes Local Housing Needs (LHN) Assessments, which confirm the extent of that local need for each settlement. These documents provide a robust indication of the level of market and affordable housing needs in these settlements. Indeed, the LPA relies upon the LHN assessments in its adopted Policy CS15 as the basis on which new, small scale housing schemes can be acceptable in principle. We would therefore urge the Planning Authority to consider allocating small sites for development in villages, to support local shops, services and community facilities and maintain populations. We note that the village of Stockton had a population of 1,391 at the 2001 Census, which fell to 1,347 at the 2011 Census. Without providing new homes, young and growing families are unable to move into the smaller villages or are forced to move away, leading to a loss of vitality and falling populations. It is therefore important that this Plan allocates sites to these settlements through a dispersal strategy, or identifies a suitable, proportionate level of growth for these small villages, over and above a simple infill policy. 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? We recommend that the threshold be based on the size of the existing village. The precise percentage will need to be tested through Sustainability Appraisal but we consider that a limit of ten dwellings may be too low. Firstly, this will represent an extremely low percentage increase for many villages. Taking the example of Stockton, the village has approximately 600 households, so an increase of ten dwellings would equate to less than 2% growth which will do little to support local services and deliver local housing needs. An increase of 10%, however, would equate to 60 new households which would add to the vitality of the village and enable population growth, without overwhelming the existing settlement. Secondly, limiting sites to ten dwellings will not deliver affordable housing, since national policy only requires affordable housing for major residential developments.

Issue S8 – Small scale development outside of the chosen growth option. 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? A threshold approach could be appropriate, to allow more small-scale developments to come forward. We welcome the acknowledgement in the supporting text to Issue S8 of the importance of small scale development to preserve the vitality of smaller settlements. The Plan also notes that allocating very small sites in a larger number of small settlements may not be appropriate, because it is difficult to predict where and when these needs will arise. We fundamentally disagree with this approach. It should be well understood by the Local Planning Authority which villages have services which are in need of support. Further, Stratford Upon Avon District Council publishes Local Housing Needs (LHN) Assessments, which confirm the extent of that local need for each settlement. These documents provide a robust indication of the level of market and affordable housing needs in these settlements. Indeed, the LPA relies upon the LHN assessments in its adopted Policy CS15 as the basis on which new, small scale housing schemes can be acceptable in principle. We would therefore urge the Planning Authority to consider allocating small sites for development in villages, to support local shops, services and community facilities. It is therefore important that this Plan allocates sites to these settlements through a dispersal strategy, or identifies a suitable, proportionate level of growth for these small villages, over and above a simple infill policy.

QS1 select the option which is most appropriate for South Warwickshire Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced South Warwickshire Councils need a clear policy to protect important environmental assets, designated and non designated sites including potential local wildlife sites. As well as a policy to enhance and restore wildlife sites. Without watering down the policy with wording such as ‘where appropriate’ and in line with the priorities of the Biodiversity Action Plan. The Councils need to plan in line with the legal requirements set out in the National Planning Policy Framework (NPPF), 25 year Environment Plan, the Governments commitment to 30% land in nature recovery by 2030, COP 27 and COP 15 and the Councils declared climate change emergencies. National Planning Policy Framework Paragraph 20d) requires ‘conservation and enhancement of the natural...environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation’ Paragraph 175. Requires Councils ‘take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries’. Q S3.2 Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Brownfield site should be given the upmost priority and areas should only be proven to be an unsustainable location if regeneration projects of the area to make it a sustainable option is not viable.

If you have any further comments, please write them here.: Warwickshire’s Greenbelt should be protected, not developed, we have and will continue to lose so much due to HS2, so using what Greenbelt land is left for housing should never be a consideration. Destruction of established wildlife habitats and biodiversity is nothing short of criminal. Use Brownfield sites for housing, and why build so many just to bring people in to the area, when we should be building more realistic affordable and social housing for residents and their families who are forced to leave due to high property prices. Leave our Greenbelt alone and use Brownfield sites, otherwise Warwickshire will become nothing more than a massive housing estate, especially Kenilworth that doesn’t have the infrastructure to support all these people who will move here

If you have any further comments, please write them here.: I fully endorse the points made above but have particular concern about the potential loss of green belt where it separates one town or city from another . Our existing town centre (kenilworth) and road network cannot possibly cope with the increased demand for health and social, services, traffic, parking etc while developments in town currently being planned and built appear to have no additional facilities within them and so it seems reasonable to assume this would be the same in further future developments as neither WFC nor WCC appear to have any regard whatsoever for local opinion, either from residents or town representatives. I would like to know how they feel this can be justified?

[Referring to a proposed site across from Leicester Lane] I am absolutely livid about this! It’s the only reason we bought this house 3 years ago [Redacted], it overlooks the fields and the estate agent swore it was green belt and wouldn’t be developed. There is not the infrastructure to accommodate this amount of increased traffic, the car congestion alone is already bad!! The schools are already oversubscribed. I would like to know how you got around the green belt protection?! [Redacted]