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

Question S5.2: New Settlements I believe that new settlements are probably the best option to go for in the SWLP. The Urban area of Leamington, Warwick and Whitnash (encompassing Bishops Tatchbrook) is already so large that local infrastructure is overwhelmed. Similar problems exist in Stratford upon Avon. However I firmly believe new settlements should not be made in the Green Belt , given the large area of non-Green belt availability. It goes against National Planning Policy Framework to see so many new settlement locations in the current consultation document posited for Green Belt land. There cannot be “exceptional circumstances” for all these. Non Green Belt options should be prioritised over any other development options in Green Belt land. Question S7.2: As to Option 1- 4 inclusive I stress that the priority should be to avoid development of Green Belt Land. The need for Green belt development in each of Options 1-5 should be considered before selecting a specific spatial growth option to fulfil NPPF “exceptional circumstances”. I do not find it acceptable to select a spatial option without first considering if there is a need to develop in Green Belt to deliver that Option. That is putting the cart before the horse. An Option should be chosen that requires less, or no, green belt development and that should be chosen even if more infrastructure work is required. To retrospectively claim exceptional circumstances are needed because there is no other way to satisfy a selected spatial growth option is not an acceptable or fair minded way to proceed. I would again state that to use climate change as justification to develop green belt land is wrong. Question S8.1: Settlements falling outside the chosen growth strategy Whilst the threshold approach to small scale development in greenbelt areas may seem an easy way to add to the required housing stock under the SWLP, I do not feel it should be permitted. You already have limited infill in the Plan. Question S8.2: Size of individual threshold developments. Given my answer to S8.1, my answer is zero in greenbelt areas. Question S10: Any other comments I find it disturbing that Issue S6: A review of the Green Belt boundaries was included without the option to comment on it specifically. Hence I wish to comment on it now. Once again I wish to state that using climate change as a reason to amend Green belt boundaries with the intention to permit development is just wrong. If forensically examined it would prove a weak argument. I am specifically opposed to development of land in the Green Belt area in and around Weston under Wetherley and other similar small green belt villages due to adverse impact on the rural nature of the North Leamington Green Belt. I further feel it is not necessary or appropriate to readjust Green Belt boundaries. In the first consultation on this subject, the exceedingly small number of respondents (561), compared to the population, is hardly a mandate to redraw Green Belt boundaries. It would be interesting to know how many of the responses came from parties that might benefit from development in redrawn boundaries.

Economic development Forecasts are difficult in such a complex area. On line demand and supply chain flexibly have already changed the mix of developments. My view is that better information about the future employment trends in different sectors is necessary to overlay onto the economic development plan in order to see where housing allocation priorities lie. Sustainability Failure to act quickly on sustainability practices will leave zero carbon targets unmet. Energy price increases will have a market impact on the sustainability and location of commercial, retail and industrial development. However in housing this is less clear and sites must be identified which meet sustainability criteria for future living. Dispersal or new settlements My view is that there will always be a mix to deliver the allocation targets. However: 1. Dispersed housing into smaller settlements must only be for community identified local need 2. Dispersed housing developments of significant size to large villages and towns must only be selected where existing (and readily improved) services, infrastructure and economic development can be shown to support it. 3. New towns and villages should only be considered in areas where sustainability can be demonstrated in infrastructure, strategic road and rail network and ready access to employment opportunities. In my opinion these should be directed close to the motorway network and consideration given to new motorway junctions to accommodate them. New settlements E1 The vast majority of new homes required in Stratford District are for in-migrants into the area. I am deeply concerned about the proposed further development of the Long Marston - Meon Vale - Quinton settlements and them coalescing into a major new town. The reason for my concerns are threefold: 1. The location is not sustainable on the test of road and rail infrastructure being in a rural area and essentially a dormitory development. 2. The location, which on its southern perimeter is bounded by the rural area of the Cotswolds AONB, essentially means all travel for work and services is north and west. There are very limited employment opportunities close to the development and the lack of infrastructure (road and rail) is an impediment to attracting quality economic development and jobs (logistics, mixed use, industrial, IT and communications). 3. The B4632 can not be considered part of a ‘strategic road network’ to the A46 and M40 corridors. It is already very heavily trafficked and regularly congested on the outskirts of Stratford. It is a route that requires passage over the historic Clopton Bridge and through the town centre. The traffic on this road is already of great concern to communities south of the town who have to rely on it to access all their day to day services, travel to work, shopping, schools and healthcare. Alternative routes are limited to minor C class roads through villages such as Long Marston and Welford on Avon.

At the outset we should state that we think it is remarkable that, with such a long and complex document and at such a comparatively early stage in the process, there is not a proper executive summary of the key issues with page references to the main document. We confine our remarks to that part of South Warwickshire in Stratford District. Our submission relates mainly to Chapter 4 of the document and the questions therein. In particular, we reject the inclusion of a site at Wood End (Revised A1) as one of the possible locations for a major new settlement. The main reason for rejecting it is the fact that Wood End is in Green Belt. 1). Green Belt The Planning Inspector who examined the last Stratford Local Plan told the council in no uncertain terms that it should only consider building on Green Belt when it had excluded other options. The Core Strategy eventually had to be re-written to favour Long Marston and Lighthorne Heath - both existing sites with residential and business opportunities. It seems that lesson has not been learnt. Yet again planners in both Stratford and Warwick seem to have gone for the “soft” option of including sites in Green Belt. They have decided a “blind” approach as far as Green Belt is concerned is appropriate. We do not. This despite the assurance given by the Prime Minister to the House of Commons on 27 July 2022: “Green belt land is extremely precious in the UK. We’ve seen too many examples of local councils circumventing the views of residents by taking land out of the green belt for development, but I will put a stop to it.” The Tanworth-in-Arden Local Development Plan 2022 and the Stratford District 2011 Local Plan agree with the para 137 of the NPPF: “The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.” The recently adopted Tanworth Neighbourhood Development Plan, which covers Wood End, goes further: 1.16. “Overwhelmingly, the evidence from questionnaires and discussion highlighted the importance to the local community of being in or near open countryside protected by the Green Belt……….” This document chooses not to regard Green Belt as an unsurmountable obstacle. The avoidance of urban sprawl and “very exceptional circumstances” are barely mentioned. Green Belt only features as one of a number of “considerations” to be taken into account at a later stage. Clearly, Warwick District has its heart already set on a Green Belt review and, according to a report in the Stratford Herald on 11 January 2023, Stratford District seems to be being swept along in its wake. It would be a welcome change if planners could regard Green Belt/The Avoidance of Urban Sprawl as something to be cherished at the start of their deliberations. A last resort when all other options have been exhausted. In our opinion, and in the opinion of many voters in Stratford on Avon, Green Belt should be regarded as an asset and not as a burden to be got round - or an annoying inconvenience to be overcome. Planners may be blind to Green Belt, but, most definitely, residents are not. 2) Damned Statistics Our Association regards the use of so-called statistics in this document as nothing short of dishonest. To make the assertions that: “37% of respondents supported the principle of new settlements, whilst 27% were against. The remainder were indifferent.” “54% of respondents supported the exploration of growth opportunities in the Green Belt, with 31% against and the remaining 15% commenting without giving an overall view.” “In the Scoping and Call for Sites consultation in 2021 there was a majority support for undertaking a review of Green Belt boundaries” This was a self-selecting sample of the kind usually regarded as worthless by polling professionals. If you ask a group consisting mainly of landowners and potential developers if they are in favour of building on the Green Belt don’tbe surprised by the result. The only surprise is that the percentage was not greater. If the emerging Local Plan is going to quote public opinion to justify its case measure it properly and fairly. Even then the results can only be a guide. 3) The Missing Options Our Association totally accepts the need for housing to 2050 and the challenge of doing so sustainably. It also thinks that promoting the use of railways rather than cars is to be preferred. In passing, we note that government has recently refused finance for the campaign to restore heavy rail along the Stratford Greenway to join up with Long Marston and Honeybourne. It is strange this document makes no mention of the desirability of this or other similar rail projects. Figure 12 shows the Stratford - Long Marston and Fenny Compton - Kineton lines as possible railway corridors but only Long Marston is recognized as having potential for expansion. We have already submitted comments on the South Warwickshire Economic Development Strategy. That document refuses to offer suggestions for possible sustainable areas of fresh growth – preferring to leave this, and the Green Belt issue, to this plan. Rather than spreading housing down the existing rail corridors in Green Belt, a forward- thinking document like this should, in our opinion, look for more ambitious projects. Obviously, these will require money from central government. We commend two suggestions which aim to build on the results of the existing Stratford Local Plan: 1) Further expansion at Gaydon. The existing industrial and residential developments at Gaydon/Lighthorne, astride the existing M40, would seem to provide a modern location for further expansion using roads, existing and new, as the Planning Inspector at the previous Stratford Core Strategy recognized. There would be the long-term opportunity to create a new six mile railway spur from the Kineton branch of the Snow Hill to Oxford/Marylebone line with a modest re-alignment of the existing junction to allow northward travel. Chiltern financed such a project to Oxford with great success. Even more environmentally sustainable than road development it might attract the kind of government finance that has previously proved elusive and would avoid putting more pressure on the M40. It might even prove attractive to Jaguar Land Rover. 2) Staying with rail opportunities in the area. Long Marston, with its mix of industrial and residential developments, badly needs a boost. The existing proposals seem to have stalled. For a very modest outlay the re-establishment of the six mile link north to Stratford and Birmingham and south to Honeybourne and the Cotswold Line to London and Worcester would give a boost to existing industries and encourage developers. It would take pressure off roads in the area. The re-laying of part of the Borders Railway in Scotland and the Northumberland Line provides an indication of the economic and tourism benefits that can be achieved by restoring lost rail services. We would urge that a full business case be undertaken to establish the benefit to cost ratio and projected cost per mile for both projects as part of the next stage of the plan. In conclusion, major expansion at the existing new settlements at Long Marston and Gaydon, exploiting the proximity of possible rail connections and existing commercial and residential developments, would mean there was no need to undertake a Green Belt Review in Stratford District for the foreseeable future. Wood End should therefore be deemed an unsuitable site for a new settlement. Co-operation between the two Councils should not mean that “one size fits all”. Throughout the document there are options to allow each District to adopt different solutions to common problems. If Warwick District wishes to undertake a Green Belt Review because of its specific needs that should not mean that Stratford District has to follow. Q-S8.2: A lower limit is appropriate

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.

Q-S5.2: Do you think new settlements should be part of the overall strategy? Yes, a new settlement or two should in principle be acceptable because it is possible to ensure that the infrastructure is provided when it is needed and more generally it would be easier to provide new housing with good access to services and creating strong social communities. But this dependent on the Council having the institutional means of ensuring that, and no mention is made of this. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? No. Where is the evidence that this will make any material difference to climate change. The analysis of the 5 Strategic Growth options does not show the focus on railways as being better on emissions. Indeed we think that in the north of the South Warwickshire area much of the movement is east-west rather than northsouth. Q-S8.1: Yes but not applicable in the Breen Belt notwithstanding the review of the Green Belt

Q-S1 – Option S1a We consider that the SWLP should identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. However, this should be based upon proportionate evidence, which must be up to date. The SWLP refers to the Warwickshire Coventry and Solihull Sub regional green infrastructure study being used to inform policies, however this study dates back to 2013, and is therefore some 10 years old. This should be updated if it is to be used for the purposes of policy making, and included in the forthcoming suite of additional evidence base documents which can be commented upon as part of the plan making process in Stratford and Warwick. Issue S2: Intensification Please select all options appropriate Option S2c – Do not have a policy which encourages intensification. Each site should be considered on its own merits to take account of site-specific constraints and opportunities. A blanket approach to a policy with an ‘in principle ‘support for intensification or even the identification of sites which are considered to be particularly suitable could be counterproductive. Whilst it is acknowledged that the current Framework promotes the effective use of land in meeting the needs for homes, this should not be at the expense of healthy living spaces, or, as advised in footnote 47, “except where this would conflict with other policies in the Framework.” Any proposed intensification, per se could run contrary to the achievement of “well-designed or beautiful places” advocated by the Framework, which places great emphasis on “the creation of high quality, beautiful and sustainable buildings and places”. Furthermore, we are concerned that higher anticipated yields from such sites resulting from an intensification policy approach could result in the allocation of fewer sustainable green field sites – which could ultimately result in failure of the plan to deliver its requirement over the plan period because of the reliance on the yield from the intensification of the site, which may, in due course not be supported due to adverse impact on living conditions for future occupiers or character/appearance reasons and so on. Issue S3 Using Brownfield Land for development Q-S3.1-Option S3.2c We do not consider that a policy should be included in the SWLP to prioritise the use of brownfield land for development. There is no such policy imperative set out within the NPPF, and as result were the SWLP to prioritise brownfield land over greenfield development it would be inconsistent with national policy and fail the tests of soundness. By way of context, it is important to note that prior to the publication of the NPPF in 2012 the concept of sustainable development was largely based upon the delivery of previously developed land, with an express sequential approach set out in PPG3 (latterly PPS3) and PPG1 (latterly PPS1). This sequential approach was specifically removed from national policy, and a more nuanced approach to sustainable development set out. There is no indication that a sequential approach is to be brought back in, despite the various revisions to the NPPF which have been published since 2012. This is because utilising brownfield land does not automatically render a proposal sustainable; and to prioritise brownfield land would be to bring forward development that does not meet the three pillars to sustainably and potentially unbalance plan strategy and plan delivery, since development would only be brought forward where brownfield land exists, not where the plan making process determined development should be. Policy can make clear that the emphasis should be on utilising brownfield land for development, but this must not be expressed as a sequential approach nor applied as such through the development management function. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold development approach is appropriate, to allow more small-scale developments to come forward? Yes. We consider that it is appropriate for small scale development to come forward outside of the chosen strategy. This allows for unidentified development (windfall) to come forward over the plan period, which has the potential to support the vitality and viability of existing communities. New development in this circumstance should not be determined by a threshold. By setting a threshold, the suggestion would be that any specific settlement has some form of capacity or limit, and therefore any development exceeding the notional threshold would be inconsistent with the plan strategy. That cannot be the case. The ability for a settlement to accommodate new development will change over time (and noting that the plan period for the SWLP is extensive, to 2050), new development has the potential to increase the ability for a settlement to absorb growth (for example bringing with it new facilities, either on site or via the S106 regime). In any event development requirements should be expressed as a minimum with no ceiling or cap. Issue S9: Settlement Boundaries and infill development Q-S9 – It is our preference for Part 1 of the Plan to review and define all settlement boundaries across the combined district. This would achieve a consistent approach and allow smaller settlements to take more proportionate growth to enhance the vitality of rural communities.

Issue I5 Green and Blue Corridors Q-S1 – Option S1a We consider that the SWLP should identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. However, this should be based upon proportionate evidence, which must be up to date. The SWLP refers to the Warwickshire Coventry and Solihull Sub regional green infrastructure study being used to inform policies, however this study dates back to 2013, and is therefore some 10 years old. This should be updated if it is to be used for the purposes of policy making, and included in the forthcoming suite of additional evidence base documents which can be commented upon as part of the plan making process in Stratford and Warwick. Issue S2: Intensification Please select all options appropriate Option S2c – Do not have a policy which encourages intensification. Each site should be considered on its own merits to take account of site-specific constraints and opportunities. A blanket approach to a policy with an ‘in principle ‘support for intensification or even the identification of sites which are considered to be particularly suitable could be counterproductive. Whilst it is acknowledged that the current Framework promotes the effective use of land in meeting the needs for homes, this should not be at the expense of healthy living spaces, or, as advised in footnote 47, “except where this would conflict with other policies in the Framework.” Any proposed intensification, per se could run contrary to the achievement of “well-designed or beautiful places” advocated by the Framework, which places great emphasis on “the creation of high quality, beautiful and sustainable buildings and places”. Furthermore, we are concerned that higher anticipated yields from such sites resulting from an intensification policy approach could result in the allocation of fewer sustainable green field sites – which could ultimately result in failure of the plan to deliver its requirement over the plan period because of the reliance on the yield from the intensification of the site, which may, in due course not be supported due to adverse impact on living conditions for future occupiers or character/appearance reasons and so on. Issue S3 Using Brownfield Land for development Q-S3.1-Option S3.2c We do not consider that a policy should be included in the SWLP to prioritise the use of brownfield land for development. There is no such policy imperative set out within the NPPF, and as result were the SWLP to prioritise brownfield land over greenfield development it would be inconsistent with national policy and fail the tests of soundness. By way of context, it is important to note that prior to the publication of the NPPF in 2012 the concept of sustainable development was largely based upon the delivery of previously developed land, with an express sequential approach set out in PPG3 (latterly PPS3) and PPG1 (latterly PPS1). This sequential approach was specifically removed from national policy, and a more nuanced approach to sustainable development set out. There is no indication that a sequential approach is to be brought back in, despite the various revisions to the NPPF which have been published since 2012. This is because utilising brownfield land does not automatically render a proposal sustainable; and to prioritise brownfield land would be to bring forward development that does not meet the three pillars to sustainably and potentially unbalance plan strategy and plan delivery, since development would only be brought forward where brownfield land exists, not where the plan making process determined development should be. Policy can make clear that the emphasis should be on utilising brownfield land for development, but this must not be expressed as a sequential approach nor applied as such through the development management function. Issue S8: Small scale development outside of the chosen spatial growth option Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold development approach is appropriate, to allow more small-scale developments to come forward? Yes. We consider that it is appropriate for small scale development to come forward outside of the chosen strategy. This allows for unidentified development (windfall) to come forward over the plan period, which has the potential to support the vitality and viability of existing communities. New development in this circumstance should not be determined by a threshold. By setting a threshold, the suggestion would be that any specific settlement has some form of capacity or limit, and therefore any development exceeding the notional threshold would be inconsistent with the plan strategy. That cannot be the case. The ability for a settlement to accommodate new development will change over time (and noting that the plan period for the SWLP is extensive, to 2050), new development has the potential to increase the ability for a settlement to absorb growth (for example bringing with it new facilities, either on site or via the S106 regime). In any event development requirements should be expressed as a minimum with no ceiling or cap. Issue S9: Settlement Boundaries and infill development Q-S9 – It is our preference for Part 1 of the Plan to review and define all settlement boundaries across the combined district. This would achieve a consistent approach and allow smaller settlements to take more proportionate growth to enhance the vitality of rural communities.

Please note this e mail as an objection to the proposed development [redacted] in Leicester lane Leamington spa. Any loss of beautiful countryside is to be deplored particularly given the chaos now being caused in this area by the high speed rail link development. A truly pointless waste of money.

Q-S1 Option S1a Identify strategic green and blue corridors in advance of the local nature recovery strategy being produced. This needs to involve local people . We need to focus on looking after the natural world - local habitat, wildlife, plant. We should not be focusing on sorting it out after destroying it. Q-S5.4 Effective railways need to be considered. Currently we barely have a service in Kenilworth so this area needs to be avoided. Better to develop in Birmingham where there will be a quick link to London.

I write on behalf of our client Thwaites Ltd, in response to the South Warwickshire Issues and Options Consultation in the interest of ‘Land to the south of Thwaites Ltd, Cubbington’ (‘the site’) and it being suitable for removal from the Green Belt as part of the South Warwickshire Local Plan Review. The Issues and Options Consultation and Call for Sites for the South Warwickshire Local Plan, is running for a period of 8 weeks between Monday 9 January and Monday 6 March 2023. The purpose of this consultation is to welcome any interested parties, Parishes, individuals, landowners and developers to inform the Local Planning Authority (LPA) of any sites within the district that they consider suitable to accommodate future housing and employment as part of the SHELAA. In this representation we discuss the suitability of the site for removal from the Green Belt to support the businesses needs as a significant employer during the Local Plan period, in accordance with the economic objectives of the Local Plan and the NPPF. It is emphasised that this representation regards the site only. It is noted from the South Warwickshire Local Plan website that a Green Belt review is not currently planned, which would lead us to assume that Green Belt release is not considered a strategic proposition. Site Location and Description The site is located adjacent to the existing Thwaites business, outside, but adjacent to the settlement boundary within the Green Belt, as shown on the map below. Thwaites Thwaites has existed for almost 80 years and now provides a significant number of jobs. The business requires specialist equipment, processes and facilities. It has and continues to invest significant capital at its existing site to achieve this and it would be very expensive to relocate to new premises. Thwaites business is for the manufacture of dumper trucks which are sold globally and has seen a significant increase in demand over the last few years. Since 2012, annual revenue has trebled to circa £95M, this significant increase in demand has been attributed to the housing market in both the UK and continental Europe, HS2 in the UK, and infrastructure projects. It is envisioned that this increase in demand will continue over the coming years as the housing shortage continues to drive house building projects in the UK for which Thwaites distributors supply machines. Thwaites single site operation has not expanded geographically and continues to provide a significant number of jobs and requires more site space to satisfy storage and logistics needs and there we would like to apply for the removal of the area of land as indicated in the attached plan. Relevant Planning Policy The current development plan for the site comprises the Warwick Local Plan (2011-2029) adopted in September 2017. Policy DS4 sets out the spatial strategy of growth in the Warwick District. The policy aims to focus growth within and adjacent to built-up areas, with the majority of growth being focused on the main urban areas of Warwick, Leamington, Whitnash and Kenilworth, with some growth being directed to the growth villages such as Cubbington. Figure 1: Warwick District Council Green Belt Plan. The site is edged in red. Black is the defined settlement boundary. This spatial strategy also takes national Green Belt policy into account. It outlines that sites in the Green Belt will be limited to those locations where exceptional circumstances can be justified. The following will be taken into account in considering exceptional circumstances: i. the availability of alternative suitable sites outside the Green Belt; ii. the potential of the site to meet specific housing or employment needs that cannot be met elsewhere; iii. the potential of the site to support regeneration within deprived areas; and iv. the potential of the site to provide support to facilities and services in rural areas. Policy DS19 of the adopted Local Plan confirms the Council will apply national guidance within the Green Belt. The fundamental aim of the Green Belt policy is to prevent urban sprawl and keep land permanently open. National Planning Policy Framework Since the submission, there has been a revised National Planning Policy Framework (‘the Framework) that was issued in July 2021. The most relevant policies are enlisted below: Chapter 13 regards the protection of Green Belt Land. Specifically, Paragraph 137 states that “the Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence”. Paragraph 138 sets out that Green Belt serves five purposes: • to check the unrestricted sprawl of large built-up areas; • to prevent neighbouring towns from merging into one another; • to assist in safeguarding the countryside from encroachment; • to preserve the setting and special character of historic towns; and • to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Paragraph 140 states “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans”. Paragraph 141 states that once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use. Paragraph 147 defines ‘inappropriate development’ as development that is ‘harmful to the Green Belt and should not be approved except in very special circumstances. Paragraph 149 sets that that “a local planning authority should regard the construction of new buildings as inappropriate in the Green Belt”. Exceptions to this are: 1. buildings for agriculture and forestry; 2. the provision of appropriate facilities (in connection with the existing use of land or a change of use) for outdoor sport, outdoor recreation, cemeteries and burial grounds and allotments; as long as the facilities preserve the openness of the Green Belt and do not conflict with the purposes of including land within it; 3. the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building; 4. the replacement of a building provided the new building is in the same use and not materially larger than the one it replaces; 5. limited infilling in villages; 6. limited affordable housing for local community needs under policies set out in the development plan (including policies for rural exception sites); and 7. limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings), which would: - not have a greater impact on the openness of the Green Belt than the existing development; or - not cause substantial harm to the openness of the Green Belt, where the development would re-use previously developed land and contribute to meeting an identified affordable housing need within the area of the local planning authority. Issues and Option Consultation Questions Policy EC1 relates to ‘directing new employment development’. Cubbington is identified as a Growth Village and the site is situated within the Growth Village Envelope as defined on the policy map. Policy EC1 relates to directing new employment development and identifies that in rural areas. Having reviewed the consultation document we wish to respond to the following questions as part of this representation. • Issue E1: Growing the South Warwickshire economy • Issue E8: Existing employment sites • Issue 11: Any other economic issues

Green Belt Considerations Joint Green Belt Study (JGBS) The most recent review of the Green Belt was undertaken in 2015 as part of the evidence base supporting the Warwick District Local Plan. This study assessed the Green Belt in Warwick District council against the five purposes of Green Belts, as set out in the National Planning Policy Framework (NPPF). The site is located in Broad area 3, which lies between Royal Leamington Spa to the south, Kenilworth to the north west, Coventry to the north and Rugby to the north east. The area contains the Registered Park and Garden at Stoneleigh Abbey, several Scheduled Monuments and Grade I listed buildings and substantial pockets of ancient woodland, including Ryton Wood SSSI. The JGBS found that the area made a considerable contribution to all the purposes of Green Belt for the reasons set out below: • Checking the sprawl of Royal Leamington Spa, Kenilworth and Coventry. • Preventing the merging of neighbouring towns in the long term, particularly Royal Leamington Spa and Kenilworth and Kenilworth and Coventry. • Safeguarding the countryside, including a number of large woodlands, such as Ryton Wood. • Preserving the setting and special character of the historic towns of Royal Leamington Spa, Kenilworth and Coventry. The historic core of Kenilworth is located on the opposite side of the town, meaning that the broad area makes little contribution to the setting and special character of Kenilworth. However, panoramic views in to the historic cores of Royal Leamington Spa and Warwick to the south are common in the southern half of the broad area and there are some distant views of the historic core of Coventry close to the northern edge of the broad area. • Assisting urban regeneration by encouraging the recycling of derelict and other urban land across the West Midlands. It is our considered view that nothing has changed to alter the conclusions of the JGBS in 2015. However, we recommend that the site be removed from the Green Belt allocation in accordance with Paragraph 138 of the NPPF. Protecting Green Belt Land The Framework also states that before considering releasing land from the Green Belt, Councils will be required to demonstrate that exceptional circumstances exist to justify changing the Green Belt boundary. This will be accessed through the examination of strategic policies but should consider all other reasonable options for meeting identified needs. These include: • Making as much use as possible of suitable brownfield sites and underutilised land; • Optimising the density of developments; and • Discussions with neighbouring authorities to ascertain whether they could accommodate the identified need. We note that in selecting sites on the edge of urban areas, the adopted plan favoured non-Green Belt over Green Belt sites where possible. However, where there were no suitable non-Green Belt alternatives, sites were removed from the Green Belt to enable development to take place. Purposes of the Green Belt Vitally the suitability of the site’s removal from the Green Belt can be demonstrated through setting the site against paragraph 138 of the NPPF, which identifies the five purposes of Green Belt land. The site is set out against each of the 5 purposes as per paragraph 138: Purpose A - to check the unrestricted sprawl of large built-up areas; The location of the site is adjacent to the existing Thwaites site and by virtue adjacent to the existing defined settlement boundary. Removal of the site would not cause a significant adverse impact on the openness of the Green Belt nor would it result in a sprawl given that the boundary of the subject site does not extend beyond the boundary of Thwaites existing boundary. Purpose B - to prevent neighbouring towns from merging into one another; It was acknowledged in the Joint Green Belt Study 2015 that the Green Belt plays a crucial role in preventing the merging of neighbouring towns. We support this general motion although there will be instances where land in the Green Belt can be released without having a significant impact its objective to prevent towns from merging since the site doesn’t project beyond the boundary of the existing site to the north. Purpose C- to assist in safeguarding the countryside from encroachment; Paragraph 140 notes that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Therefore in the case of the subject site and on behalf of our client we ask that the land in question is removed from the Green Belt to support the business and allow its growth over the Plan period. Purpose D - to preserve the setting and special character of historic towns; and Releasing the site from the Green belt will not harm the setting and special character of historic villages and historic buildings, and, in turn, will not cause damage to their historic landscape. Purpose E - to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The site’s release from the Green Belt will not prevent or prejudice urban regeneration. Whilst we understand and appreciate the value of utilising derelict and other urban land rather than developing the Green Belt.

Summary Overall, it is recommended that the land shown in the accompanying location plan be removed from the Green Belt. It is required to enable Thwaites, an established business (who has been operating for almost 80 years), to expand in a sustainable way and continue to provide employment for the existing community throughout the plan period. Indeed, its removal from the Green Belt would not cause significant harm to the five purposes of including land in the Green Belt. Coupled with this expansion of the business is considered to be in accordance with policy EC1 which supports sustainable growth and expansion of existing rural businesses and enterprise. We note from the South Warwickshire Local Plan website that a Green-Belt review is not currently planned as part of the evidence for the Local Plan. However, we would hope on the basis of the contents of this representation the site will be considered for removal from the Green Belt.

I am particularly concerned about plans to build on green belt land. My understanding was that green belt land was designated as such to protect such land in many ways. I was also under the impression that the current government have indicated that greenbelt land should not be built upon. Here are my concerns in detail: The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 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 proposals 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 were rejected less than six years ago. The Planning Inspector’s 2017 response to the current Local Plan for Warwick District states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p. 18, para 91). It also states that: “Development of the land in question would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. It would have a significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p.34, para 201). This high value area has already suffered significant damage to openness and character with the construction of the HS2 railway line causing interruption of farmland and wildlife habitat. Further adverse development in the area would compound the significant adverse impacts that the Planning Inspector referred to in 2017. If anything, arguments for maintaining the Green Belt’s contribution to the openness of the countryside, food production and biodiversity are stronger now than six years ago when these comments were made. It is not in line with current Government policy. The Government has recently asserted that local planning authorities are not expected to review the Green Belt to deliver housing. 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. It skews development away from affordable housing in the areas where people work. The Government has also made a “brownfield first” pledge 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 would like to respond to the Issues & Options Consultation. As a young person who has grown up in Old Milverton, I am concerned about the development plans for Green Belt land for multiple reasons. The beautiful fields provide amazing opportunities for exercising and walking dogs; without this land we would have lots of people needing to drive elsewhere in order to give their dogs sufficient exercise, which is very un-environmentally friendly and also a massive inconvenience to people who regularly walk around the fields (of which there are many). For me, most importantly it is a place to relax and clear my mind, which has been extremely beneficial for my mental health throughout my exam period and other stressful times in my life, and replacing the fields with more concrete jungle will completely ruin the serenity of the area. I’ve met so many new people on walks, made friends with lots of people in my local community (some of which even led to helping me get work experience on local farms which aided my university applications) and I’m sure many other people use the fields for social reasons, which is again incredibly important for mental health. I also fear that the destruction of local wildlife and construction of new buildings will have negative implications on the environment, such as air pollution, noise pollution and light pollution, even if the effects of these aren’t seen immediately.

QS-7.2: The Consultation does not make the case for why Green Belt development is necessary. All five of the spatial growth options place development in the Green Belt. The first 3 options place a majority of the development in the Green Belt. This ignores the contribution of the Green Belt to the character of Warwick District as well as to the health and wellbeing of residents. Developing this land would take these benefits away from future generations. In particular, the Green Belt land north of Leamington Spa should not be developed because: 1) It fulfils all of the five purposes of Green Belt land 2) It is high quality agricultural land which should be protected. This is even more important given the national food security issues. 3) The Planning Inspector rejected the proposals less than six years ago. He said that villages should maintain their separate identities and that any further reductions in the gap between here and Kenilworth should be avoided. He recognised that any development of the North Leamington Green Belt would involve a substantial expansion of the built up area into currently open countryside to the north of Leamington Spa. Every day we see the effects of HS2 nearby. This has already damaged the openness and character of the local area. Any further adverse development should not be allowed to happen. S10 It is more important than ever to appreciate and value the Green Belt’s contribution to the openness of the countryside, food production and biodiversity. The consultation document does not sufficiently justify why developing the Green Belt is necessary and does not offer any alternatives. I am concerned that there was no option to comment on Section 6 (review of Green Belt boundaries) and I am concerned that no options were put forward which sought to avoid or minimise Green Belt development.

I have noticed on the Call for Sites initiative that a large parcel of land has been put through for light instrustrial use, B4115 opposite Dial House Farm, Ashow, CV8 2LE. REFERENCE ID 195 SWLP Call for Sites. I would like to object at this stage to this land being considered for development as part of the local plan. 1. Greenbelt – Inappropriate development is harmful to the Green Belt. It is difficult/ impossible to see how light industrial use activities would enhance the Green Belt. The proposed development site is adjacent to ancient and protected woodland. The proposed development would be a significant eyesore and not in keeping with trying to maintain and preserve the Greenbelt and open green spaces in line with current policies 2. Strong Village Opposition to Development – the Ashow Parish Council hosted a meeting on Saturday with regard to the Neighbourhood plan. This meeting was very well attended. One of the exercises was to place markers on a map of the village and surrounding areas with regard to where the community would and would not be happy to see development. Without exception, every resident placed red markers in all fields which would have capacity for building. It was clear to see that the residents of Ashow do not feel we need or desire any development in the village. 3. Highways – B road access and a very busy junction opposite the Chesford Grange would not make this suitable of fit for purpose for HGV traffic in the rural countryside. HS2 traffic is not permitted along this route for this very reason. I strongly urge you to not consider this land for proposed development. It would be totally inappropriate in this area, not supported by any Policy and is overwhelmingly objected to by a significant number of villagers – which was entirely evident in the Parish Council Neighbourhood Plan meeting held on Saturday 4th March. If this goes ahead, it will only be a matter of time before a request for ‘change of use;’ is submitted and the land is then turned into another sprawling housing estate eating up the ever decreasing fields and greenbelt between Kenilworth and Leamington

Q-S1: Please select the option which is the most appropriate for South Warwickshire. Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced 3.18 Rainier consider Option S1a to be the most appropriate for South Warwickshire, where information can be used from the soon to be updated Sub-Regional Green Infrastructure Strategy, as well as additional evidence, to help identify Green Infrastructure corridors which can be used to help determine the growth strategy for the wider area. 3.19 Furthermore, Rainier recommend that the plan identifies which Green and Blue Corridors identified within the Plan could be utilised as Suitable Alternative Natural Green Spaces (‘SANGs’). This is due to the statutory requirements of Biodiversity Net Gain (‘BNG’), which requires all new developments within South Warwickshire to compensate for any impacts on habitat, either through enhancing existing habitats or by creating new ones (if impacts are unavoidable). 3.20 It would therefore be beneficial for the Plan to identify the appropriate SANGs that can be used by the developments (that are unable to deliver BNG on-site) which will help South Warwickshire meet its growth needs over the next few years, in advance of the Local Nature Recovery Strategy being produced.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire 3.21 Rainier support the principle of using brownfield land for development, however it should be acknowledged that there is insufficient brownfield land capacity to meet the growth needs of South Warwickshire up to 2050. Rainier therefore support Option S3.2c above. 3.22 As recognised within the plan itself, brownfield sites are frequently found within town centres, and can therefore often accommodate a higher density development. However, a strategic employment site needs to be located in strategic locations, adjacent to the SRN and other transport options. 3.23 It is therefore recognised that although brownfield land could be prioritised for some development types within the plan (for example, residential development), it is not always the most suitable option for other uses such as employment. Ultimately, the plan should seek to prioritise the most sustainable and suitable sites to meet the growth needs of South Warwickshire.

Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire. 3.24 As set out earlier in these representations, Rainier are concerned that the consultation document is too narrowly focused on the delivery of solely residential development, with insufficient consideration for how employment growth across South Warwickshire will be delivered; this concern is also reflected within the growth options presented above. 3.25 For example, Growth Option 3 is labelled ‘Economy’, however this Option is focussed on the delivery of homes ‘in close proximity to employment’; rather than seeking to direct employment and economic growth to the most sustainable and suitable locations, which are usually focussed close to existing motorway junctions and the wider strategic highways network. 3.26 As established within the NPPF (Paragraph 20), strategic policies should set out an overall strategy for the pattern, scale, and design quality of places, making sufficient provision for employment, housing, retail, leisure, and other commercial development. Rainier are concerned that the Plan does not currently consider each of these elements to be delivered alongside each other, and ultimately there has been too much focus in respect of housing. 3.27 It is therefore recommended that the growth options above are updated, to reflect how all development needs within South Warwickshire can be met, in accordance with an updated Vision for the Plan which recognises the importance of employment growth to support the overarching strategy for the Plan.

I am writing with regards to the Call for Sites initiative as I have been made aware that a that a parcel of land has been put through for a minimum of 10 house in Grove Lane, Ashow, CV8 2LE. REFERENCE ID 193 SWLP Call for Sites. I would like to exercise my right to strongly object at this stage to this land being considered for development as part of the local plan. 1. Greenbelt – this development would destroy part of the green belt. This field forms an important part of the conservation area of the village and within the greenbelt. It would be inappropriate development which is harmful to the Green Belt. It is difficult/ impossible to see how houses on this site would enhance the Green Belt. 2. Conservation area – there are a number of wildlife habitats in the village, specifically within our cherished greenbelt areas; this area forming part of that. There are badgers, foxes, deer and muntjacs that reside in the village and removing any greenbelt land would impact this. The character of the Ashow Conservation Area should be preserved and we should be looking to retain the character of the area. There are numerous listed buildings that are adjacent to the land in question and important that the quality of these areas are maintained. 3. Strong Village Opposition to Development – the Ashow Parish Council hosted a meeting on Saturday with regard to the Neighbourhood plan. This meeting was very well attended. One of the exercises was to place markers on a map of the village with regard to where the community would and would not be happy to see housing development. Without exception, every resident placed red markers in all fields which would have capacity for building. It was clear to see that the residents of Ashow do not feel we need housing nor development in the village. 4. Highways – There is no public footpath along Grove Lane. The road is single carriageway. The road is often blocked due to visitors parking on the street, ceptic tank vehicles, oil delivery vehicles struggle to get past – not least if there was ever a need for the emergency services. The access to the site would either be the very narrow lane adjacent to Long Row or from Grove Lane – neither of which are suitable or practical given the single track nature of the access roads. The volume of additional cars in the village is completely impractical – the roads are congested now, and do not have capacity for more vehicles 5. Services – there is no mains drainage, and no gas supply in the village – villagers having to rely on Ceptic Tanks and Oil for heating 6. Previous Proposed Development (Application Number W/17/0778) – I refer you to a previous planning application on this land which had a significant volume of opposition. If this development goes ahead, it will be the start of urbanisation of this historical village so I strongly urge you to not consider this land for proposed development. It would be totally inappropriate in the village, not supported by any Policy and is overwhelmingly objected to by a significant number of villagers – which was entirely evident in the Parish Council Neighbourhood Plan meeting held on Saturday 4th March. There can be absolutely no justification for this development and destruction to take place in Ashow.

Issue S1: Green & Blue Corridors Whilst Historic England is supportive of the identification of Green and Blue Corridors, we consider that the Local Plan should also recognise the value of the historic environment in contributing to the multi-functionality of these corridors via cultural heritage, recreation and tourism, through assets such as historic parks, gardens and canals. Issue S2: Intensification Historic England promotes positive and proactive approaches to heritage within design and planning frameworks and is therefore supportive of Design Codes to inform development and densities within particular areas. These can be useful tools to encourage heritage assets to be embraced within development to make contributions and enhancements to new environments. Issue S4: Growth of Existing Settlements As part of the evidence base to inform the spatial strategy Historic England is pleased to see that a ‘Heritage and Settlement Sensitivity Assessment’ has been undertaken for some settlements across South Warwickshire to assess the sensitivity to new development on the existing heritage and landscape character. Whilst this is a good starting point to assess the potential for growth of certain settlements, we consider that it should be used as an initial filtering, with those with potential for development being assessed further. Further assessment work should include consideration of historic settlement character and also of non-designated heritage assets that are not recorded on the HER that may contribute to historic character of settlement, which can be identified through the use of LiDAR. Therefore, we specifically suggest further consideration of: • Character of the historic core of settlements and how new development could sustain character and any significance it derives from its setting - Bearley is a good example, as to the north of Snitterfield Road an area of ridge and furrow contributes to the immediate setting of the historic core and we therefore suggest that the scope for new development should be located north or west of Grange Road. Sense of place is also important to inform how new development may sustain or enhance – Henley-in-Arden being a good example of this, as although a north-east extension has been ruled out, the prominence of castle views and linearity of settlement probably mean that extensions to the north-west and south-east would present significant heritage challenges too. • Capacity for a settlement to accommodate new development. Even 50 homes in a small settlement could have a big impact on character – Beausale is a good example of this, as it is a dispersed settlement and any concentration of development would impact that character and therefore Beausale would be better suited to individual piecemeal developments. • Unrecorded archaeology on LiDAR. For example, much ridge and furrow is unrecorded, but contributes greatly to the character of historic settlements and the landscape in this area. Therefore, development on areas of ridge and furrow should be avoided wherever possible. We also consider that further work on characterisation for Stratford-upon-Avon would be helpful, as the assessment describes at some length where the designated heritage assets are but makes no clear distinction between what has been built and the consents which are still being built out. In relation to the consideration of which direction the settlement should be allowed to expand, assessment of the impact of the recent and approved expansion of the town and how that affects the overall character of Stratford should be considered. Consideration should therefore be given to the overall impact of future development on the ‘experience’ of the place: the word used in the NPPF definition of setting of a heritage asset. We also suggest that the description of the development of the town could be further improved by including the key contribution of tourism since the 18th century to the town’s prosperity, so that the description reflects the essence of what that represents in terms of the experience. In relation to Kenilworth, we consider the assessment to be a little stronger on the overall setting of the place. However, although the assessment rules out expansion to the south-east, developing to the east would also need to consider Stoneleigh Park Registered Park and Garden and the Roman Scheduled Monument, whereas development to the south-west is likely to impact on the deer park of Kenilworth Castle (if located to the west of Rouncil Lane) and therefore impact on the significance of the Scheduled Monument and Registered Park. Additional general comments on the heritage assessment include that the keys to the maps use the correct labelling for listed buildings (Grades II, II* and I) whereas the text consistently refers to them using Arabic numerals and should be amended. Further comments on the ‘Heritage and Settlement Sensitivity Assessment’ in relation to specific growth options are set out below under ‘Issue S7: Refined spatial growth options’. Issue S5: The potential for new settlements We note that Table 6 – ‘Summary of potential locations for a new settlement’ includes Conservation Areas, but no other heritage designations such as Scheduled Monuments (SM), Listed Buildings or Registered Parks and Gardens (RPG). Historic England advises that heritage evidence will be required in relation to the selection of any of these locations for a new settlement and that this should include consideration of the impact on both designated and non-designated heritage. In relation to the potential locations for new settlements, we consider that location C1 Kingswood/Lapworth is especially sensitive, given that it lies between the Grade I Packwood House and Grade II* RPG to the west and the Grade I Baddesley Clinton House and Grade II RPG and SM to the east, both with many other Grade II listed buildings and structures also present. The area is also characterised by canal infrastructure and just to the south of the settlement of Kingswood is the junction of the Grand Union Canal and the Stratford-upon-Avon Canal, with a number of listed structures associated with the canals, such as locks, bridges and cottages. Historic England would therefore have concerns about the impact on the historic environment of a new settlement of around 6,000 dwellings in this location. Issue S7: Refined spatial growth options Historic England notes that some locations/settlements within certain growth options have not been assessed in relation to heritage or settlement sensitivity and some of the smaller settlements may indeed be ruled out for further development once a heritage assessment has been undertaken. For example, King’s Hill, South of Coventry, is included within Options 1, 2 and 4, but development here is likely to impact on the setting of a medieval settlement Scheduled Monument. In addition, Option 5, ‘Dispersed’, includes many smaller settlements, some of which have a considerable wealth of both designated and non-designated heritage assets. In relation to some of these smaller settlements change of the amount indicated is likely to have an effect on historical character and assets and we recommend that any significant growth at the following settlements is avoided: Great Walford, Lower Shuckburgh, Priors Hardwick, Sherbourne, Wappenbury and Wormleighton. Other settlements included in Option 5 were we have particular concerns regarding potential impacts on Scheduled Monuments and where integrating new development is likely to present challenges due to impact on the historic environment are as follows: Alcester, Aston Cantlow, Baginton, Beausale, Brailes, Bubbenhall, Butlers Marston, Farnborough, Halford. Hampton Lucy, Henley-in-Arden, Honington, Kenilworth, Long Itchington, Stoneleigh, Stretton-on-Fosse, Tiddington, Tredington, Wasperton and Whichford. For other settlements further detailed assessments to inform impacts on the historic environment are advised. These include Fenny Compton, where there is evidence of a medieval settlement that would be of regional significance; Harbury, Napton-onthe-Hill, Quinton and Tysoe, which all have surviving ridge and furrow. Therefore, if Option 5 is taken forward we would recommend that a heritage assessment exercise (to include consideration of HER & LiDAR data and historic settlement capacity/form) is undertaken and that the views of your chosen specialist archaeological adviser are sought at an early stage. Issue S9: Settlement Boundaries and infill development Historic England recommends that any consideration of the alteration of existing settlement boundaries should include assessment of the potential impact of the proposed alterations in respect of the historic environment. The Local Authority will need to be satisfied that it has fully considered the implications of proposed alterations to settlement boundaries in terms of the potential impact on designated and nondesignated heritage assets in its assessment work as the Plan progresses.

Q-S1: Please select the option which is most appropriate for South Warwickshire Crest Nicholson supports option S1a. The Councils should identify at the earliest possible stage in the development of this Local Plan which assets it wishes to protect, along with a clear rationale and justification for the selection. This should ensure that the preferred development options are not unduly constrained or compromised at a later date and thereby reduce delays to progression of the Local Plan. Q-S2: Please select all options which are appropriate for South Warwickshire Chapter 11 of the NPPF encourages effective use of land, including: taking into consideration the need for different types of housing; the desirability of maintaining an area’s prevailing character and setting; and the use of minimum density standards for city and town centres and other locations that are well served by public transport. Crest Nicholson therefore recognises that there is role for the intensification of development in certain areas of the Local Plan area as part of the wider strategy. However, development site character and context will vary significantly across the Local Plan area, both within town centres and outside of the town centres. Planning policies will need to be sufficiently flexible to be able to accommodate this. Accordingly Crest Nicholson supports option S2b, to enable the well-planned best use of available land, incorporating intensification where appropriate but without prejudicing the need to reflect context and character on a site-by-site basis, particularly on the rural fringes of settlements. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Paragraph 119 of the NPPF is clear that planning policies should make effective use of land, including as much use as possible of previously-developed or “brownfield” land. Furthermore, NPPF paragraph 120 states that planning policies should give substantial weight to the value of using suitable brownfield land. Nevertheless this should be viewed in the context of NPPF paragraph 73, which identifies that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as extensions to existing villages and towns, provided that they are well located. Although significant encouragement is given to the development of brownfield land, it is still necessary to provide an adequate justification for the use of brownfield land in accordance with the strategy for the sustainable distribution of growth within the Local Plan area. It should not the case that brownfield land should be considered over all other options if the specific sites are not suitable, viable, deliverable or sustainable locations for housing in line with the Council’s strategy. In particular, the deliverability of development on brownfield land can be significantly impacted by existing ground conditions and the necessary associated site clearance and mitigation works. This can result in delays to delivery and greatly increase development costs, thus negatively impacting on scheme viability and wider housing delivery across the plan period. To ensure a plan led approach, the Council’s strategy should be to follow a clear locational strategy that promotes sustainable development, which includes the optimisation of brownfield land where appropriate, whilst also acknowledging the role that greenfield land should play. This approach is considered to be a variation of option S3.2a. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? As included in response to QS3.2, NPPF paragraph 73 identifies that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as extensions to existing villages and towns, provided that they are well located. The growth of existing settlements, to take account of the existing services, facilities and infrastructure that is already in place, therefore needs to be part of the overall strategy. Crest Nicholson supports the existing main settlements being part of the overall Local Plan strategy and the preferred Spatial Growth Option. As set out in Option F (Main Urban Areas) of the Scoping for the South Warwickshire Local Plan (2021) there is a significant benefit arising from delivering new homes and jobs in and around the five main urban areas in South Warwickshire, as well as the edges of the adjacent urban areas of Coventry and Redditch. Crest Nicholson contends that whilst Coventry is not within the Local Plan area, it is immediately adjacent to the Local Plan area, and is connected to this area both in terms of infrastructure and commuting patterns. The consideration of land on the edge of Coventry is also important at this stage of the process given that there is a recognition that the Local Plan area may need to play a role in accommodating the sustainable growth of and / or the unmet need from Coventry. It is noted that ‘Evolving the Spatial Growth Options – The Story So Far’ Topic Paper (August 2022), concluded that Option F should not be taken forward as a stand-alone scenario but ‘urban areas however remain a component of all the other growth scenarios’ (Appendix 2). As such it is maintained that all of the Growth Options set out in the Issues and Options document should include growth along the boundary with Coventry, as shown in the adjacent figure extract from Option F. Option F can be combined with any of the Growth Options (albeit has particular synergy with Growth Option 4: Sustainable Travel and Economy), given the ability to locate homes close to, or on public transport links to, existing jobs and potential new job locations. As set out in the Issues and Options consultation document a ‘growth option where jobs and homes are co-located means that more people are given the option of living close to their place of work’ (page 96). Crest Nicholson is keen to highlight that its site to the South of Westwood Heath Road, which is predominantly within the ‘South Coventry’ area has the potential to deliver additional housing within this area, as a modest extension to its existing committed housing development. Further details of this are set out in the accompanying Vision Document. Q-S5.2: Do you think new settlements should be part of the overall strategy? The delivery of new settlements should be taken into consideration as part of the wider strategy, given the potential that they offer to make a significant contribution to new housing delivery. It should however be recognised that the delivery from large strategic sites can be slow in the early stages of the new Local Plan period. As set out in the Lichfields ‘Start to Finish Report’ (Feb 2020) the average time from the validation of first application to completion of the first dwelling for a scheme of 2,000+ dwellings is 8.4 years. As such it is crucial that a sufficient number of smaller sites are identified to address the first 10 years of the plan period, and to complement the delivery of larger strategic sites and / or new settlements throughout the Local Plan period. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? In relation to the location of new development in general, and not just limited to the locations of new settlements, and as identified in the response to Q-S7.2, Crest Nicholson is supportive of the opportunities arising from locating new development close to public transport corridors, including rail corridors. The South Warwickshire authorities benefit from a large number of railway stations which provide links to a multitude of locations across both HMAs and the wider region. Issue S6: A review of Green Belt Boundaries Whilst a question is not posed for Issue S6 (Green Belt), Crest Nicholson would support the undertaking of a review of the Green Belt in order to inform the assessment of the most suitable and sustainable sites for release from the Green Belt within South Warwickshire. The planning system must make land available in the right places and for the right form of development. The undertaking of a Green Belt Review is an essential part of the process of making developable land available in the most sustainable locations. NPPF paragraph 142 highlights that when drawing up or reviewing Green Belt boundaries the need to promote sustainable patterns of development should be taken into account. National policy currently identifies that Green Belt boundaries can only be altered in exceptional circumstances through the preparation of Local Plans, and this provision is expected to remain through the current review of the NPPF, along with the Sustainability Appraisal requirement for LPAs to review and assess reasonable alternatives. In establishing the housing requirements for an area, particularly if affordability concerns are to be addressed at larger settlements surrounded by Green Belt, Green Belt cannot currently be used as: the sole justification to direct development elsewhere; or as the sole justification to artificially suppress housing delivery; or the rationale for distributing housing to less sustainable locations. The 300,000 homes a year target set by the Government, and the subsequent response to the consultation on housing numbers in December 2020, identifies Coventry and Birmingham as being two key areas for housing growth to meet the target. South Warwickshire is adjacent to the Coventry City Council administrative area. Whilst the evidence base to underpin the new Coventry Local Plan is not yet available it is expected that Coventry City Council will be unable to meet its housing needs in full and this unmet need should be considered as a key part of the strategy for the South Warwickshire Local Plan from the start of the Local Plan-making process. A Green Belt Review should form part of the evidence base to inform the Local Plan. The delivery on Crest Nicholson’s existing housing commitment immediately to the south of Westwood Heath Road is on land previously removed from the Green Belt on the edge of Coventry, and will contribute to the housing needs of Coventry City. The current planning permission (W/22/0055) relates to most, but not all, of the existing Warwick Local Plan allocation H42. There is still land in the southern part of H42 which has been removed from the Green Belt for development which has not yet been subject to approval for residential development. Crest Nicholson has undertaken a further review of environmental and technical considerations relating to the remaining area of allocation H42 and considers that the additional vehicular traffic movements that might arise from further development in this location can be accommodated within the capacity of the local highway network and that the landscape and heritage impacts of development in this location can be mitigated and accommodated to avoid significant harm arising. This is set out further in a Vision Document that has been submitted in support of these representations. Crest Nicholson considers that it is important that the South Warwickshire Councils give full consideration to maximising the capacity of land already removed from the Green Belt for development within existing Local Plan allocations as part of the development plan strategy, along with the potential to remove further land from the Green Belt in sustainable locations in order to meet the development needs arising. Q-S9: Please select the option which is most appropriate for South Warwickshire There will be a need for Part 1 Local Plan policies to be applied in a consistent way across the whole of the Local Plan area. If policy provisions seek to control what development can occur within and outside of settlement boundaries then there would be logic to ensuring that the approach to setting settlement boundaries is also consistent across the Local Plan area. There is an opportunity for this consistency to be achieved in the first instance through the Part 1 Local Plan. This approach will however need to acknowledge that the South Warwickshire Councils are currently not planning to identify all of the allocations needed to meet the development requirements for the Local Plan period through the Part 1 Local Plan and that some of these will need to be met through the Part 2 Local Plan and / or through Neighbourhood Development Plans. As set out in the response to Q-I2, such an approach is seen to be counter-intuitive, but if this is carried forward then the Part 1 policies will need to ensure that it is made clear that any settlement boundaries shown within the Part 1 Local Plan can be subject to review through the Part 2 Local Plan and Neighbourhood Development Plans in order to accommodate the additional site allocations deemed necessary to meet the housing needs of the Local Plan period.

Subject PLANNING AND GREEN BELT Message 1) I query the SWLP decision that Green Belt land should be included for housing development -contrary to Government policy 2) little is said about safety - pedestrian, motor vehicle and cycles - my brother was nearly killed in 2019 crossing the A452; crossing from the blackdown island busstop is daily 'a danger because of careless driving. 3) the clearly defined current separation between Leamington, Kenilworth and Cubbington should be maintained 4) allottments at Old Milverton should be maintained as contributory to food sufficiency combined with health and welfare of users 5) infill development around Blackdown conflicts with the building and cultural historic origins viz large Victorian (?) buildings with their diversity of plantings - much of which is already being degraded 6) little is said about public transport: traffic has increased in number and speed (speed limits), current usage at Blackdown and, I imagine, Old Milverton is by car, 2 and 3 car/households increasingly common AND the frequency of bus routes on the A452 at Blackdown have been cut from 5 to 1 often making it difficult for the elderly (e.g. me) to walk to Leamington and Kenilworth.

Firstly I am unsure why Green Belt land is being proposed for this development. Surely this area is providing exactly the conditions the green belt is supposed to. That is keeping a separate identity between the local towns, providing wildlife habitat which HS2 has already negatively impacted, and farmland which is of a high agricultural value but is a scarce resource and should be being maintained for future food security. It seems reckless in the extreme when we take into account these points plus the fact that people are using the area for recreation which positively impacts on mental and physical heath. In surveys residents say the green belt and footpaths through it are one of the things they most value about living in the area. In addition the Government has made a brownfield first site pledge which would free up land more in keeping with the actual needs of local people, and not developers, for affordable housing close to their places of work and recreation. The government has also said that local planning authorities are not expected to review the green belt for housing, so why is the planning authority in Warwickshire doing just this? I hope that bearing in mind I have attempted, though unsuccessfully, to use your online system that you will take my comments into account for your consultation. My final observation would be why are trying to make Leamington Spa an unpleasant place to live?

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? Threshold of 20 dwellings Whichever growth strategy is pursued, and these representations do not seek to comment on the options presented, as the Issues & Options paper acknowledges, with a plan period running to 2050, omitting Stratford and Warwick’s rural hinterland in respect of housing growth options will fail the rural community; both economically and socially. It will also fail to ensure the health and well-being of communities in several ways. It is appreciated that South Warwickshire’s main towns and larger villages provide a wider range of services and facilities than the smaller villages and hamlets across the rural area. They can more readily meet the day to day needs of communities and serve neighbouring areas in providing accessible services and employment opportunities. However, sustainability is more than the ability to access services, facilities and employment by means other than the private car. This is particularly so given the increasing number of the working age population working from home, especially in rural areas – a point acknowledged in the Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA) – paragraph 4.41. Paragraph 85 of the NPPF recognises that rural areas are not static places, stating that, “Planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. In these circumstances it will be important to ensure that development is sensitive to its surroundings, does not have an unacceptable impact on local roads and exploits any opportunities to make a location more sustainable (for example by improving the scope for access on foot, by cycling or by public transport). The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.” Paragraph 78 of the NPPF also states that, “In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs.” The Country Lane and Business Association (CLA) report, “Sustainable Communities: the role of housing in strengthening the rural economy” was published in 2022. The report highlights the issues rural communities face in comparison to their urban counterparts - "a population ageing at a faster rate, proportionally fewer affordable homes, pressure on house prices from second home ownership and a larger gap between house prices and wages.” The report, in referencing member surveys and statistics from DEFRA, CPRE, and the Affordable Housing Commission, writes that, “The pricing out of the younger generation has resulted in rural areas ageing faster than other parts of the country, yet with the least provision of suitable homes for the elderly. The loss of young people and full-time occupiers in rural areas continues to contribute to the closure and loss of key services and amenities, which will only be exacerbated by the pandemic. For rural areas to thrive, there needs to be an adequate, available and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.” The demand for the younger generation to move to rural areas has likely increased as a consequence of the pandemic and the acceptance (and positive encouragement by many businesses) of home working but it exists. The HEDNA identifies this at paragraph 4.37. “More generally the market is varied with people of all ages renting within the authority however there is a definite trend of younger single people, couples and young families looking to rent within the area. Most of those seeking rental properties in Warwickshire live locally or used to live locally and are looking to move back into the area, looking for a return to a more rural life.” It’s pertinent that the HEDNA notes this demographic look to rent, raising the question of affordability and accessibility to the type and tenures of housing available for sale within rural areas. The older populations in South Warwickshire are also comparatively high compared to nearby authorities (Coventry, North Warks, Nuneaton & Bedworth and Rugby). The figure below is taken from the HEDNA and shows Stratford having the highest proportion of people aged 65 and over. Warwick sees the highest proportion aged 16-64 (outside Coventry) which the report notes is linked to its student population. When that transient student population is taken into account, the proportion aged 65 and over increases. The HEDNA doesn’t provide a detailed analysis of the rural housing situation in South Warwickshire. The lack of a detailed study examining the issues for South Warwickshire’s rural communities is, it is considered, unhelpful in fully understanding what benefits would be derived by a chosen growth strategy. It is however clear that the rural area, and its smaller villages and hamlets are places that cannot afford to stagnate. Like their larger neighbours, they need to remain dynamic and vibrant places that afford residents the ability to move into appropriate and accessible housing without having to move away or be prevented from moving in. Issue S8 recognises this in explaining how, “Small scale development can play a role in preserving the vitality of smaller settlements, for example by providing additional pupils for the local school, new customers for local facilities, and by helping ensure people can stay living locally when their accommodation needs change.” Issue S8 states that it is expected that limited infill within settlement boundaries will be permitted in the SWLP and this would be seen as “the baseline position”. This is supported but it will not, alone, be sufficient to address the rural housing issues. It is questionable how much housing can be delivered within the rural settlements by way of infill without cramming developments in to otherwise more spacious, low density environments. Moreover, and more importantly, developments would tend to be very small scale and below a threshold in delivering affordable housing, housing for older persons or the accessible housing for younger people and families to access. For that reason, there has to be an alternative strategy and thus full support is given to an alternative approach which would allow for more development at rural settlements. To achieve an appropriate and balanced housing type, tenure and mix, it will necessitate housing outside but adjacent to defined settlement boundaries. This approach would reflect policies in North Warwickshire’s new Local Plan (2021). Policy LP2 (see below) allows for, or rather does not prohibit, development outside settlement boundaries. Guiding policies and “planning judgement” are to be applied on sites with a wider planning balance given to a particular proposal, the benefits it delivers to any given location and any harm that might be derived. It allows a more fluid decision making exercise which provides for the local communities whilst affording protection over disproportionate growth the settlement it adjoins. With SWLP having a plan period to 2050, this approach would be helpful to Stratford and Warwick in ensuring their villages provide the type of housing to meet the full needs of their population. The Examination Inspector’s final report into the North Warwickshire Local Plan provides useful context to this policy. “90. However, as submitted, Plan policy LP2 does not recognise the flexibility encouraged in the NPPF2012 and in the PPG towards housing provision beneficial to ‘rural communities’. Despite its proximity to several more populous areas, much of the Borough is rural in character and comprises small settlements dotted about the landscape. Furthermore the PPG sets out how all settlements can play a role in delivering sustainable development. It guides that ‘blanket policies’ restricting development in some settlements, or preventing their expansion, should generally be avoided. 91. Similarly, with reference to NPPF2012 paragraph 158, as submitted Plan policy LP2 is based on ageing evidence as opposed to the USSA (an updated assessment of the availability of services and facilities settlement by settlement). By consequence the restrictive approach to enabling development only within established settlement boundaries defined pursuant to policy LP2 is inconsistent with national policy. It would also undercut Plan policy LP8, which accords in-principle support to windfall development of 60 dwellings per annum (‘dpa’). An uplift in housing delivery in the Borough over recent years has, in large part, resulted from permitting development outside of settlement boundaries.” Whilst the inspector references NPPF2012, it is not considered the latest NPPF or PPG differ so greater so as to represent afundamental departure from this approach. Moreover, South Warwickshire has a similar settlement pattern albeit arguably to a greater extent. That is to say that it too is “rural in character and comprises small settlements dotted about the landscape.” Further viability work will be needed on the threshold to ensure that sites are deliverablein a manner that delivers the homes that are needed. That will include some market housing, including “aspirational housing”, but will be concentrated on homes for the ageing population, those in housing need (affordable) and accessible market housing to younger people and families wish to stay in, or move to, the rural area. If a threshold is fixed with no flexibility there is a possibility that sites are brought forward at artificially low numbers to avoid a disproportionately high (and unviable) number of affordable homes. The approach set out above, Policy LP2 (North Warwickshire Local Plan) provides this flexibility. A more nuanced approach that allows communities, councillors, and officers to better weigh the benefits. A scheme of 15-20 houses for example might deliver a wider range of housing and be able to provide other local community benefits, contributing perhaps to a play area or improved village facilities It is understood that some settlements, hamlets with only a handful of homes, are unlikely to provide the basis for growth. Local Service Villages and others that provide gravity for growth should however benefit from modest and proportionate growth, particularly with such a long plan period. It is therefore submitted that a threshold of 20 homes in these villages would provide the flexibility whilst affording protection to character and the social cohesion of settlements. In setting a threshold at this number, it would encourage better design and quality, a wider range of housing, including bungalows, and would deliver more affordable homes in the rural areas at quantities that would more likely be attractive to Registered Providers (noting that RPs tend to struggle to manage and maintain stock if they’re in small numbers dotted across a wide area). In setting a threshold at 20, protection to settlement and landscape character can still be maintained. Like in North Warwickshire, proposals would be considered “on their merits”with a planning balance applied. Without allowing for modest growth on the edges of villages, and relying on infill only, there is a genuine risk of stifling rural communities. Preventing older people downsize, younger people and families stay in their communities or move their, and those with housing needs to access the accommodation they need in the places they have a social connection with. It will also limit the ability for wider benefits of development to be passed on to communities by way of planning obligations. In giving this further consideration as the plan progresses, it might be advisable to review whether considering broadband availability as part of the sustainability appraisal would be helpful; particularly in light of the increased and ‘here to stay’ home working model.

I write to formalise my objection to the planning of housing development near Blackdown/Lillington between Sandy Lane and Leciester Lane as specified in the South Warwickshire local plan consultation. The National Planning Policy Framework is clear in its guidance that an area of Green belt should retain its status if it meets ANY ONE of the five purposes of Green Belt. These are; To check the unrestricted sprawl of large built up areas To prevent neighbouring towns from merging into one another To assist in safeguarding the countryside from encroachment To preserve the setting and special character of historic towns And to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Clearly, the green belt land surrounding the north of Leamington meets all of the above criteria and any proposal to redraw the boundaries would be against the NPPF guidelines. The Green belt status of land around North Leamington Spa performs well in protecting urban sprawl. It provides a clear boundary between Leamington and Kenilworth. North Leamington boasts an array of character and heritage assets which would be significantly harmed by the removal of the green belt status it currently enjoys. The town's best interests and its special character must be protected. The Green belt land offers recreational and health benefits to the community, as a local resident I frequently use the footpaths. The footfall still remains higher than before lockdown. The land in the Green belt area is of great value for agricultural farming and should be safeguarded for this purpose. In addition, the land is home to a wealth of wildlife and habitats. HS2 works have already had a hugely detrimental effect on the environment in the area, impacting ancient woodlands and wildlife habitats with no benefit to the area. The remaining Green belt land must be protected. Deviations from the current plan are unsustainable given the lack of infrastructure to North Leamington. Consequently, the Local Plan process should address its focus to development opportunities outside of the Green Belt (none of the proposals investigated have been included within the consultation document). Additionally, it is evident that land to the south of Leamington Spa, which sits outside of the green belt, has ample scope to meet housing demand, as well as already benefitting from infrastructure upgrade and reinforcement as a result of the current Local Plan. The fields and woodland between Sandy Lane and Leicester Lane are home to much wildlife including Birds of Prey and muntjack deer which we see regularly. Development of this area would be destrying their habitat.

I wish to raise my concerns over the The South Warwickshire Local Plan Issues and Options Consultation: I live in Bearley which has been designated as one of the 22 small settlements and the plan is to build between 50 and 500 houses in the village. Looking at the map it appears these houses will be built on the only playing field in the village which is at present in regular use by football teams, dog shows and various other village activities. To lose this facility for housing needs is totally unacceptable. The map also shows houses will be built in the newly planted Heart of England Bearley Community Woodland. Living in a time of emergency climate change this woodland must be maintained and other more suitable sites made available for housing needs. There is no infrastructure to support 50 to 500 new houses in Bearley. Bearley has no shop, no school, no GP Surgery and a very limited bus and train service. Please reconsider the options so Bearley will not suffer major negative impacts.

Dear Sir/ Mme I object to the proposed development in Old Milverton. Building in this area is a destruction of the open space available to the population of Leamington Spa. To build on the green belt is not acceptable and show no consideration for Leamington Spa residents who use the space for walking, jogging & relaxation. Building on the green belt will push the local residents to drive their cars for long distance and cause more pollution in order to reach the country side and breath fresh air. Please, keep our green belt safe from [Redacted] builders.

Issue S2: Intensification Q-S2: Please select all options which are appropriate for South Warwickshire 3.4 Under this issue, the IO document does not pose any specific questions, but instead identifies three options for developing a policy to support the intensification of existing areas. 3.5 National policy provides advice on achieving appropriate densities as part of the overall objective to make efficient use of land 2 or for optimising the density of development in city and town centres and other locations that are well served by public transport 3. This includes taking into account the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change4, as well maintaining the viability of development5. It is also advised that it may be appropriate to set out a range of densities that reflect the accessibility and potential of different areas, rather than one broad density range 6. 3.6 In this context, it is clearly the case that some localities more central to existing built-up areas may be more predisposed to accommodate more intensive development than other locations. Nonetheless, delivering development at increasingly higher densities will inevitably lead to potential impacts on the prevailing character and setting of existing settlements. Therefore, whilst increasing densities could increase the supply of housing, this should not be seen as the only option. In this context, there is clearly a role for development that is brought forward on the edge of existing settlements that can be designed in order to integrate with existing areas but also help to create distinctive places in their own right. 3.7 Consequently, RPS recommends a design-led approach to establishing strategies on density. Density is a function of good design and there is no reason to take an alternative approach when devising local policy through the SWLP. On this basis, any policy approach should be informed by an assessment of the character of different areas because character is not uniform across the plan area. This is in preference to any blanket or an ‘in-principle’ approach. Similarly, there should not be any overarching priority to intensify or densify existing urban areas because other evidence, principally the Urban Capacity Study, shows that the development needs of the SW area will not be met through urban-focused / brownfield growth alone. This is discussed in the response to Issue S3 below. 3.8 RPS therefore would favour Option S2a, which would direct any policy response to localities where intensification is considered to be appropriate, but which recognises that density should be design-led informed by the local context. 2 NPPF2021, paragraph 124 3 Paragraph 108 4 Paragraph 124d 5 Paragraph 124b 6 Paragraph 125b

Issue S4: Growth of existing settlements Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.19 Yes. 3.20 There are a number of national and local factors that clearly demonstrate the appropriateness of a strategy which directs future growth to existing settlements within South Warwickshire 3.21 Paragraph 69 of the NPPF recognises the important contribution that small and medium-sized sites can make to meeting the housing requirements of an area, which can be built out relatively quickly. This provides clear support for directing future growth to appropriately-sized sites on the edge of existing settlements and which can deliver sustainable development. And paragraph 85 also provides support for sites and locations that can meet the community (and business) needs of rural areas adjacent to or beyond existing settlements, and where sites are physically well-related to settlements such opportunities should be encouraged where suitable. Consequently, national policy clearly provides sufficient support and policy direction for focusing growth at or around existing settlements. 3.22 The IO document hints at what the emerging development strategy might comprise based on commentary set out in the second paragraph under this issue (on page 43). This states that the SWLP will seek to: “…maximise the capacity of its existing urban areas in order to meet our development needs to 2050 (see Issue S2). However, in deciding upon the best distribution strategy for new development within South Warwickshire it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements, potentially alongside and in combination with other options such as new settlements (see Issue S5).” 3.23 In light of the findings of the Urban Capacity Study as discussed under Issue S3 of this submission, even when the capacity within existing urban areas on previously-developed land has been assessed it is clear that this will not be sufficient to meet the needs of the South Warwickshire in the long term. It is therefore inevitable that development around the edges of existing settlements will be required, given these provide opportunities to deliver sustainable development on largely unconstrained land which can be built out quickly, or where larger sites can deliver a steady quantum of development over a period of time in order to help maintain delivery against identified housing targets. This can be achieved at lower Quinton, including on Goose Lane, Lower Quinton site. 3.24 Based on the foregoing analysis, RPS contends that focusing growth as part of the emerging development strategy on existing settlements, aligns with national policy and offers clear potential to meet the development needs of the area, in light of the acknowledged constraints on land supply within settlements. The strategy should therefore incorporate locations for growth around and on the edge of existing settlements where local services and facilities are already available in close proximity to communities in order to achieve wider sustainable development objectives. 3.25 RPS also highlights that the growth that is required cannot be met solely within existing settlements identified in the IO document, as evidenced in the Urban Capacity Study. In this context, any 20-min neighbourhood policy should be worded with sufficient flexibility to consider the potential that sites can bring to create 20-min neighbourhoods, rather than only considering the existing situation as a constraint on the distribution of growth. 3.26 Consequently, the SWLP should extend its search to include other settlements which are currently acknowledged as being sustainable locations, notably Lower Quinton, that can create 20-minute neighbourhoods. On this basis, Lower Quinton should be incorporated into a revised version of the Settlement Analysis document.