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

Q-S3.2 In response to the question, the most suitable answer is a hybrid between the first two options. In line with the Framework brownfield land should be prioritised and the preference should be that brownfield land which accords with the growth strategy or is sustainably located is the first choice. However, where this is not possible but there is still need for development and existing built form should be utilised, this should still be encouraged and allowed to be brought forward. Q-S5.2 Noting the need to deliver, it is expected that new settlements will form part of that plan, but in order to ensure a seamless delivery throughout the plan period, the strategy will need to demonstrate a variety of sources. This is because of the notably long lead in time for new settlements actually delivering new houses compared to smaller scale schemes. Q-S8.1 & S8.2 For schemes falling outside of the growth scheme, there needs to be a mechanism to allow them to be brought forward. However, the size of the individual site should not be limited by a policy and each site should be considered and assessed on its induvial merits. Q-S9 The settlement boundaries should be reviewed and revised as part of the Local Plan Part 1, to provide an up to date position for which the plan can be based and enable a more accurate implementation of the Part 2 which could then seek to make further revisions or tweaks to the boundaries at a later stage. Looking at this element as a whole though, it would provide a standardised position across the district rather than the authority lead differences in interpretation of boundary designation.

Q-S5.2: Do you think new settlements should be part of the overall strategy? 3.40 RPS wishes to reiterate its position that it does not object to new settlements forming part of the development strategy in principle. Nonetheless, RPS suggests that caution should be applied in considering new settlements as part of a broader strategy for distributing growth in South Warwickshire. This is because unforeseen issues can occur that can delay progress on new settlement / strategic allocations, for example in Stratford-upon-Avon. In this case, the Core Strategy allocated two new settlements at Gaydon/Lighthorne Heath (2,300 homes) and Long Marston (2,100 homes), 30% of the adopted housing requirement of 14,600 dwellings. However, since 2011 (the base date of the current plan) these two new settlements have only delivered 343 dwellings, just 3.4% of the total housing delivered in the district up to April 20228. This is reflective of the lead-in time needed to bring forward larger, strategic sites that is often under-estimated at the forward planning stage. Alternatively, smaller sites which can harness infrastructure already available are not as dependent on the delivery of strategic infrastructure. 3.41 The distribution strategy should therefore also ensure that the needs of local communities can be met through smaller development directed and brought forward at established sustainable settlements that can be delivered relatively quickly, and thus a greater mix of different sized sites should be encouraged to deliver a significant proportion of the required growth in the SW area over the plan period. This includes the Goose Lane, Lower Quinton sites being promoted by Redrow Homes, a national house builder with extensive experience of delivering housing across the Midlands and South Warwickshire. 8 Stratford-upon-Avon Authority Monitoring Report 2021-22, Table 13 Issue S6: A review of Green Belt boundaries 3.42 RPS notes that the IO document does not include any specific question regarding potential for changes to the Green Belt in South Warwickshire. Nevertheless, national policy9 makes provision for alterations to existing Green Belt boundaries through the updating of plans where the need for changes to Green Belt boundaries is established in the strategic policies. This is normally done through a Green Belt review to inform the development of the spatial strategy and identification of site allocations. 3.43 In this respect, the IO document makes clear that to achieve a growth strategy that addresses the vision and strategic objectives for the Plan, a Green Belt study to review the existing Green Belt boundaries would inform and help to refine the growth options that are set out within the issues and options consultation to enable a preferred approach for South Warwickshire to be established. 3.44 Nevertheless, regardless of whether any Green Belt is released is taken forward, there are opportunities outside the Green Belt where growth can be directed. RPS considers that Lower Quinton would be an acceptable settlement for growth that should be taken forward in the SWLP. 9 NPPF 2021 paragraph 140

Call for Sites Information To accompany the sites submission in the Call for Sites event, we would like to take this opportunity to highlight the significant benefits that would be delivered by the proposed development of two dwellings on this site, which are as follows: • Utilises a Previously Developed Site. • Reduces the spread of buildings on the site. • Reduce the footprint of built form on site. • Well related to existing dwellings • Forms part of the existing built form of Long Marston. • Located in a sustainable settlement • Provide short-term delivery of housing, increasing the local housing stock. • Established existing access. • Provision of much required equestrian facilities to support the dwellings. • High-quality and sensitive design, that improves the visual appearance of the site. • Provides a local economic benefit during the construction phase and with the new residents. • Potential to reduce vehicle movements from the site. • Potential for biodiversity enhancements and improvements.

Issue S8: Development coming forward outside of the spatial growth strategy Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? 3.67 In response to this question, RPS does not support any maximum threshold as this could potentially limit the provision of much needed affordable housing and also limits potential to deliver wider benefits from large scale development resulting in better sustainable outcomes. Issue S9: Settlement Boundaries and infill development 3.68 Under this issue, the IO document indicates that there may be a need to alter existing settlement boundaries to take account of a new growth strategy up to 2050. National policy provides limited assistance to local planning authorities or stakeholders in how to deal with setting or amending settlement boundaries. 3.69 The IO document presents two options. Option S9a would save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Option S9b would review, within this Part 1 Plan, which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 3.70 The IO document makes clear that this plan review relates to part 1 strategic policies only, including strategic allocations and / or new settlement locations, and not non-strategic policies and allocations. On this basis, RPS would favour Option S9a – settlement boundaries should be reviewed at the Part 2 review stage. Given this option refers to the ‘emerging SAP’ RPS assumes that the SAP is still likely to be progressed and adopted including alterations to some settlement boundaries, prior to an immediate review of those boundaries in short order in the Part 2 SWLP. This is logical as the Part 2 SWLP will need to ensure the settlement boundaries are suitably robust to allow growth to be accommodated up to 2050, as opposed to the SAP which only addresses development needs up to 2031 (and only for Stratford-upon-Avon district). 3.71 Furthermore, in order to provide sufficient clarity and to reduce the risk of ambiguity in the Part 1 version, the next iteration of the SWLP (the preferred option draft plan) should make clear which settlement boundaries will need to be reviewed in light of the quantum of growth to be directed to each respective settlement (to deliver the spatial development strategy) and the capacity of those settlements to suitably accommodate that growth within the existing boundaries. RPS prefers option S9b. Issue S10: Any other development strategy issues Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire: 3.72 The preamble states that Chapter 4 of the IO document sets out various options as to how the development needs to 2050 (e.g. infrastructure, jobs and housing) might be met. The approach to doing this is split into two sub-sections covering 15 ‘issues’ across both topics; on relating to ‘Development Requirements’ and the other ‘Development distribution strategy’ for the area. 3.73 Paragraph 16 of the National Planning Policy Framework (NPPF) requires that plans contain policies that are ‘clearly written and unambiguous’. In order to establish a clear and unambiguous plan it is critical that the approach to strategic policies follow a logical process. Whilst the title of this chapter may refer to ‘needs’ scant reference is made here to the nature or scale of development needs that should be addressed in the SWLP. Specifically, there is very little, if any, consideration at the top of the document to the growth needs of the area in terms of the level or scale of growth to be planned for in the SWLP. Instead, after setting out the draft vision and objectives in chapter 3, the IO document moves straight into considering issues that have a very limited relationship to the growth needs of the area. RPS would suggest that the five issues identified under ‘Development Requirements’ are generic topic-based factors that do not inform the identification of the growth needs for the area or the requirements or targets that might be necessary to address those needs. It is therefore unclear why these considerations have been given such elevated status at the beginning of the document. 3.74 RPS notes that issues relating to the number of homes and jobs that might be required, and the evidence base to justify the approach, is set out in chapter 5 of the IO document (RPS responds to this under separate questions). Whilst providing some clarity, RPS would suggest that given the importance of setting out the growth strategy (or options at this stage) a more sensible and logical approach would be to consider the issues relating to the overall development needs of the area in quantum terms first, before then moving on to consider what the requirement should be in light of the various ‘issues’ i.e. constraints, as identified here. This then provides a clearer and more logical basis for considering the spatial distribution of growth (and options) considered later on (Issue S7). 3.75 At present, therefore, the way the IO is structured is illogical and confusing and does not help the reader to understand the approach being proposed. RPS therefore recommends that the next iteration of the SWLP is reorganised to provide a clear position on the growth strategy at the outset, including the scale of need and the requirements defined to meet that need and which respond to the needs of both market areas covering the two Districts. This will provide a coherent basis for the spatial distribution strategy, taking into account the various issues identified. 3.76 RPS would also reiterate its previous comments regarding the methodology used for analysing the selected settlements and that moving forward, the next stage of plan-making must be more transparent regarding the choice of settlement and site option.

8 GROWTH AT LOWER QUINTON 8.1 This section explores Lower Quinton as a whole, as well as providing more details about the proposals RPS and RH will be providing through the masterplanning process. Lower Quinton 8.2 Lower Quinton is a civil parish in Stratford-on-Avon and resides in close proximity to settlements named throughout the document such as Meon Vale and Long Marston. For the purpose of this plan, Lower Quinton has been paired with the smaller hamlet of Upper Quinton, recognised under the collective title of ‘Quinton’. As we have noted, Quinton has been outlined as an Option for Dispersal in Chapter 4 of the Issues and Options Document. 8.3 Lower Quinton is well served by local facilities including a village hall, public house, medical practice, a primary school and a post office. As well as hospitality services such as a hotel and a bed and breakfast. Beyond the settlement, the village is close by to the neighbouring settlement of Meon Vale. This recently expanded settlement contains further services, including a convenience store, education and a leisure centre. Importantly, Meon Vale also supports an area of substantial employment through the Business Park, and is also adjacent to the Quinton Rail Technology Centre. 8.4 Getting beyond the village, Lower Quinton is well served by Bus Routes. Main Road running west in Lower Quinton connects to the B4632 which provides a direct link into Stratford-on-Avon. These roads are served by a bus service that runs approx. every hour, Monday to Saturday daytime. As well as this, the B4632 to the south and the Main Road to the west are served by a bus service that completes one return journey or more daily Monday to Friday. Collectively, RPS considers that Lower Quinton supports a number of day to day services, but also benefits from a number of overlapping features which highlight the sustainability of the settlement for growth. 8.5 As previously mentioned in Chapter 4, the settlement would be justified in a number of spatial development options. Going forward, RPS considers that the Councils should reconsider the role of Lower Quinton in relation to the spatial development options 1, 2, 3 and 5, and consider the role that the settlement can make as part of the emerging Local Plan.

1. USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: The proposed development in Henley-in-Arden uses development in the Green Belt incorrectly to resolve structural planning problems in the district. Henley lies between two much larger urban developments in a section of Green Belt land which serves to prevent urban sprawl extending such that the developed envelopes extend to such an extent that they join. To the south, there is extensive white space on the outskirts of Stratford upon Avon, for example, which is ideally suited to development that meets the needs of a modern economy that is responsive to the environmental demands and the new working patterns that have emerged as imperatives in recent years. Development of brownfield sites around existing urban envelopes is consistent with modern planning policy that co-locates living, working and leisure spaces, and preserves the integrity of the nearby Green Belt and all of its benefits. Stratford District Council itself highlights the evidence that supports this argument: “Unemployment across the District is low, with 0.3% of workers claiming jobseekers allowance in May 2016. This is lower than the UK average (1.8%) and West Midlands average (2.2%). There is an imbalance between the number of jobs in the District and its working population. An increasing number of residents commute to higher paid employment outside the District, while lower paid jobs are often filled by people coming into the District from adjoining areas. These commuting patterns impose significant pressures on the road network. Employers in and around Stratford-upon-Avon can struggle to recruit staff into lower paid and part time roles and cite the absence of affordable commuting options, particularly outside of peak travel times, as a barrier to filling vacancies.” 2. ERODES THE COMMITMENT TO THE PRESERVATION OF THE GREEN BELT The West Midlands Green Belt wraps around Birmingham, the Black Country and Coventry and extends to a ring of towns beyond the conurbation. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch (apart from small areas of land to the west of Mappleborough Green), Bromsgrove, Solihull and Warwick. The settlements of Alcester, Henley and Studley are excluded from the Green Belt. Commitments from Stratford and Warwick in the existing planning frameworks reiterate a commitment to the integrity of the Green Belt and the prevailing government guidance and policy in respect of the Green Belt. It is critical that the Green Belt around Henley is preserved for its environmental benefits and the health and social benefits that it brings to residents. The proposed development is inconsistent with commitments made in the existing planning policies. 3. SIGNIFCANT INFRASTURCTURE LIMITATIONS AND CONSTRAINTS Traffic Limitations: Existing Plans to Match funding has been secured to calm traffic on the High Street in an initiative to impose during the first six months of 2023 a 20 mph speed limit on the High Street and commuter ‘rat run’ cul de sac roads that lead off the main artery. It is counterintuitive to simultaneously restrict the flow of traffic through the town – a demonstrated need in response to recent traffic safety issue – and at the same time expand the volume of traffic resulting from increased housing development around the town. Poor Bus Links: The bus and train infrastructure is barely sufficient to sustain the existing population, before considering an additional 2,000 residents which might result from the proposed development. The X20 bus service runs 12 buses a day on a weekday and covers the North – South route between Stratford and Solihull. Bus passengers requiring to travel East – West to Redditch and Warwick are required to travel to the end of the north or south routes and then change to another service. Stratford District Council agree – the 2018 SDC Transport Strategy reports that “A key barrier to bus use is journey length and issues of punctuality and service reliability which are exacerbated in Stratford-upon-Avon by congestion”, which is central to the operation of any bus routing to service Henley-in-Arden. Further, SDC reports that “bus passenger facilities … are currently insufficient for the volume of passengers….”. Impact of Closure of the M40 and other Congestion: With the current level of housing, any closure of the M40 south of the M42 junction leads to the diversion of traffic off the motorway and through the town, predominantly using the north-south axis along the High Street. Statistics show that the M40 is the subject of a temporary closure between 3 and 4 times a year. Roadworks anywhere in the town – typically driven by servicing the antiquated drainage system and other infrastructure – currently creates significant delays in the town. Additional development will have an adverse impact on the existing street scape within Henley. Inability to Expand or Widen Existing Roads to Accommodate Traffic: Henley-in–Arden is a medieval market town with a strong architectural heritage reflected in the North – South road axis and the listed buildings which line the A3400 and High Street. The listed buildings which exist along the main roads in the town preclude any expansion or widening of the road to accommodate increased volumes of traffic arising from increased development and volume of housing. Road Safety: An increase in development in or around Henley-in-Arden will lead to an increase in traffic of all modes to service population movement around a market town based around two intersecting roads. A brief review of the traffic accident statistics for Henley in Arden for the last five years shows 25 incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all of which centre on the High Street and the crossroads at the South of the town. An increase in population of the scale proposed by the draft Plan would inevitably lead to an increase in road traffic casualties. Car Parking: Car parking is an acknowledged problem in Henley-in-Arden, where the existing historic housing prevents the development of extensive car parking and on-street parking on the High Street predominates and cars have been forced into small off-street parking facilities – such as that behind the Co-op store. The proposed plan makes no accommodation for the resultant car traffic that would be generated by extensive development around the town. Air Quality and the Environment: Development of the scale proposed will have a disproportionate and adverse impact on air quality and other factors driven by additional traffic from the aggressive development proposed by the town. Propensity to Flooding: Henley-in-Arden is famously susceptible to flooding, and certainly more so than other sites and locations proposed in the plan. The SFRA highlights that Henley is one of the most sensitive areas in the Stratford District to the fluvial impacts of climate change. The town rests at the base of a hilly catchment area providing an obvious outlet for when the River Alne floods, as it did most notably in memory in 2007. Additional development would increase the impact of that flooding and place greater demands on the surrounding environment in the event of flooding. No Potential to Future Proof the Infrastructure: There is no obvious solution to the problem of future-proofing any development proposed in Henley-in-Arden. Ageing water and sewerage infrastructure means that there is little chance of expansion or the development of the infrastructure of the future, particularly electric charging points for cars and the support of renewables. 4. LOCAL SERVICES ARE INADEQUATE TO SUPPORT PLANNED EXPANSION: An increase in the housing stock in Henley-in-Arden such as that proposed in the draft Plan would require additional infrastructure investment, most obviously in schools and medical facilities. Henley in Arden School is part of the Arden Multi-Academy Trust. It has a capacity of 700 pupils and yet already has 710 pupils enrolled. Expansion would inevitably be necessary to sustain development of the extent proposed and local government would need to provide funds. The existing medical practice moved from the High Street to the existing site in 1990, and access is via a footpath from the High Street or via car through a housing estate to a council run car park. Again, the site of the existing facility and the lack of potential for expansion into surrounding space means that expansion in Henley-in-Arden would require a new medical facility in a new location. Any expansion of either of these facilities or the commission of new sites would inevitably lead to an increase in the risk of road, pedestrian and traffic incidents as a direct result of the crossroads and road configuration which dominates the town. 5. ABSENCE OF A FOCUS ON LOCALISM: The outline proposals make no reference to even the sense of the principles of localism in the Henley-in-Arden community and run contrary to local sentiment. Those responsible for the development of the plan must provide opportunities for communities to influence decision-making. support placemaking and. deliver services that reflect local requirements. The scale of the development proposed is completely inconsistent with the scale of the existing town and the development of the population to date. Between 1975 and 2015, the population of Henley grew by 14.3%, and grew even more strongly in later years where between 2000 and 2015, it grew by 10.2%. Using data and projections from 1. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Center for International Earth Science Information Network), the population in 2022, stood at 2,571. Assuming an average of 3.5 heads occupying a lower estimate of 500 additional houses in Henley-in-Arden as proposed in the Plan, the population of the town would grow by 68%, which is completely disproportionate development. The plan ignores Stratford Council’s own observations about the importance of Henley’s heritage and the impact of further development upon it. The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan of September 2022 observes that “The setting of some of (the) assets, particularly the castle and church, are still currently experienced within the historic open agricultural landscape. It is therefore recommended that development of the land beyond the north-eastern edge of the settlement should be avoided.” There are also similar observations about the land to the south-east and south-west of the town which are completely contrary to the scale of the development proposed in the plan. Similarly, there is little consideration of the sites north of the Warwick Road (reference HEN.02 in the Stratford Heritage Assessment) where the RED assessment risk of both harm to surviving Ridge and Furrow and harm to archaeological monuments runs contrary to the proposed sites offered for development to the East of the town. The economy of Stratford upon Avon is delicately dependent on visitors and those in search of rural tourism – the strength of demand is such that the town has its own Heritage Centre for visitors and queues for the locally-made ice cream regularly generate queues that extend up the High Street. Extensive development of the type which is proposed would likely jeopardise local businesses and a tourism-centred town: Solihull was originally a pleasant town in the Green Belt – literally ‘Urbs in Rure’ – but development without reference to local concerns has let it evolve into something much different. 6. INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable.

Under the South Warwickshire Local Plan (SWLP) Consultation we see there there has been a ‘Second Call for Sites’ and that… 'Sites submitted in this second Call for Sites should not duplicate previous submissions which are already recorded on the interactive map.’ We have checked the interactive map and would confirm that the Parish Council has already considered sites within our neighbourhood area on the said map and had already lodged our objections to all of them being considered as possible reserve housing sites with this having also been the conclusion of SDC for its 2020 SAP when none were deemed suitable. The site to the East of Snitterfield Street in Hampton Lucy has now been brought back for consideration as a potential reserve site as part of SDC’s 2022 SAP Review but we have indicated our objection to this again on what we consider to be relevant planning grounds. We appreciate that our comments on these sites have not been officially called for at this stage but, for belt and brace purposes, we wanted to advise you of our position so that they can be recorded again if necessary at this stage. We understand we will have a further opportunity to comment on the SWLP in the future and will welcome this.

Please note that I strongly object to the Wootton Wawen development plan. I understand that there has been a change in the government’s position on village expansion plans and that Michael Grove has made changes to the Levelling Up and Regeneration Bill including: - greater protection for the Green Belt with changes to the NPPF - emphasis on brownfield first in order to protect greenfield development - the abolition of top-down housing figures acknowledging that they are ‘unrealistic’ - greater involvement of local communities in planning and especially in local plans Development of some 400 homes would be catastrophic for the village, our residents and visitors. Whilst I am not against change per se, there are some things that we need to preserve both now and for future generations. Wootton Wawen is a very old village, boasting a Saxon Church and numerous historical buildings. It is still very much ‘a village’ and if this is destroyed by building new homes, it will be lost forever. We should not be destroying our beautiful countryside, our ‘green and pleasant land’, and the farms which we need to supply an ever expanding population. Every town and city has derelict buildings and disused sites which should be re-developed first. Wootton Wawen is prone to flooding and by adding further development, there is potential to exacerbate the problem. This impacts not only on people’s homes but transport too. Furthermore, the village school does not have the facilities for an increased numbers of pupils. Villages and village life should be preserved for all to enjoy.

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

QS4.1 Growth of existing settlements – Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S8.1 – Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 – Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land,which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt. Those of us living in Weston under wetherley and surrounding villages are already having our rural lives blighted by the devastation to the countryside caused by HS2. We see first hand the impact on our wildlife agriculture & businesses .It’s unfathomable that further destruction of this green belt land is even being considered .

It has recently come to my attention that as part of the updated Local Plan, a second call for development sites in Warwickshire, interactive plan has been prepared. I have concerns about one of the sites in Stratford-upon-Avon, titled; Little Clopton in the Avenue/Clopton ward. Changing this site from agricultural to residential would be a significant (potentially Major Adverse) change to the outlook and character on the nearby public footpaths, some located in the Welcombe Hills. Alongside this, the Birmingham Road from the A46 junction to the town centre suffers from various traffic issues due to several factors; likely including the additional housing at the northern end of the Birmingham Road and more recently in Bishopton. The updated Environmental Bill places greater importance on the habitats and ecological features with every development site, considering this location and its proximity to the Welcombe Hills, developing this site would be damaging in a number of ways to the existing setting here. There is a mature copse/small woodland and mature native hedge boundaries to all the fields, all housing a variety of local fauna and mammals and providing continued benefits to local environment. • What consideration has been given to the visual and character impact of changing these agricultural fields to an area of residential properties? • Has a review of the additional traffic impact, as a result of these fields being developed into the town/local area been considered? • Can the local schools, surgeries etc cope with further increases? • Has any consideration been given to the environmental and ecological impact with the changing of these fields? Further consideration and support should be given to farmers to retain and maintain their land in a profitable way, instead of forcing sales for development and change of use. I would welcome your speedy response and any documents you have relating to the suitability process when selecting development sites and specifically the Lower Clopton site mentioned above.

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

I am writing in regards to the proposed house building on the green belt with planning that is currently in place in Henley-In-Arden and would like to put forward some concerns I have regarding this; I realise there is a housing shortage in the UK , but can you please provide the reasoning for such a massive building program on the Green Belt in such a compact area? Can you confirm that all brown field sites have been explored and none found in the area? This proposed house building on the Green Belt is diminishing the beauty of Henley-in Arden by reducing the greenery and scenic value that residents and tourist alike so admire. We all pride ourselves on living such a scenic characterful town. The Blackford Hill area is extremely popular with walkers, both local and tourists, building houses on fields with public footpaths and historical importance such as the Mount, will deter people from utilising these wonderful attractions. How many houses are going to be built as the numbers portrayed are so far apart ranging from 500-2000, With such a high number of houses the impact to residents and the Henley in general will be huge, can you please provide a proposed plan and schedule of the house building? Henley already consists of approximately 1800 houses so an increase of 500, the lowest proposed number, is an increase of nearly 28%. What impacts will this increase have on residents? Will there be new Doctors surgeries, Hospitals, schools, dentists, parking, and local transport. Do you have any evidence that these issues have been addressed? A major concern is flooding. My property is located at the base of a field that is earmarked to have houses built on it. When I purchased this property I was informed that due to the clay soil I would never be able to extend or build on my land. When it rains presently the water run off from the hill floods my garden (I do have photographs to show this). We have had a trench dug to reduce the flooding, but as you can see it is still major problem. If houses are built on the adjacent field then drainage will be compromised further and the flooding will be worse for my property. Has the Environmental Agency carried out flooding risk assessment on Blackford Hill and the fields either side and adjacent properties? if so, can I have a copy this document. The flooding occurs on the other side of Blackford Hill as well where there are a number of properties located, in addition, Arden Road also floods when we have rain. Historical records of rainfall and its effects exist presently for Blackford Hill. The council will be held responsible if it proved that the building on the green belt has exacerbated flooding in the Blackford Hill area. Can you please provide evidence of ecological surveys on the proposed green belt? What is the impact on wildlife? Wildlife encountered on daily basis include deer, muntjacs, badgers, foxes, pheasants, partridges and birds of prey. Is this proposed building on the green belt in line with Teresa Coffey, Secretary of State for the Environment, five year environmental plan? Has a risk assessment been carried out for transport at the Blackford Hill site entrance? Manoeuvring out of properties in this area requires vehicles to reverse on to the main road, A4198. There has been two accidents over the past twelve months where vehicles have crashed and damaged my property. If traffic is queuing to turn onto the site this will create a hazard to residents. Please provide a copy of the risk assessment associated with this road and site entrance. Henley presently has a traffic issue with the volume of traffic particularly at rush hour period, with the proposed house building numbers, what strategy has the council put in place to cope with the increased traffic flow? Has extra parking been earmarked for Henley? What estimations have been carried out to ascertain pollution/emission level increases? Do these levels of pollution exceed the councils and the government's emission targets ( see Pollution and Environmental quality, GOV.UK press release 31 January)?

Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area, It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is SO small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Yes for settlements outside the chosen growth strategy a threshold approach is appropriate which would allow for small-scale developments to come forward during the plan period as such developments are important to preserve the vitality of smaller settlements. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? We feel that a limit of 10 dwellings which has been suggested is too low a figure as it does not allow the threshold for affordable housing to be met. Encouraging the development of affordable housing district wide should be encouraged and as such we would recommend a limit of 20 dwellings which would allow affordable accommodation to be built whilst allowing developments to remain viable.

2.1 Whilst it is noted that the consultation document states (page 2) that “Land which was submitted in the previous Call for Sites exercise in 2021 should not be provided again unless there are proposed changes to the boundary or the proposed use”, additional technical work has been undertaken on the land parcels which we consider relevant to Council’s assessment of the sites. Thus, these representations highlight and emphasise the suitability, availability and achievability of the land controlled by our clients north and south of Welsh Road West, Southam (Site Ref 453). 2.2 In doing so, we wish to highlight areas where the Council’s evidence base does not reflect the thorough technical work undertaken by our client which confirms the suitability, availability and achievability of the land north and south of Welsh Road West, Southam. 2.3 The thorough technical work accompanying our representations demonstrates that the land is appropriate for inclusion as an allocation for delivery of between 140 to 190 dwellings on the southern parcel and between 280 to 375 dwellings on the northern parcel (based on density range of 30-40dph). Development of the site(s) can come forward as an integral part of the role to be played by Southam as a Main Rural Centre in helping to meet identified housing needs, in a sustainable location, during the plan period. 2.4 Focusing some of the housing growth at Southam would contribute to sustainable patterns of development in helping to meet identified housing needs within the South Warwickshire area during the plan period (including unmet needs from neighbouring authorities (especially the Cities of Birmingham and Coventry)). Such an approach would acknowledge the suitability of Southam for growth due to its range of local services and quality public transport services to other towns within the plan area and beyond including Leamington Spa and Rugby. 2.5 Furthermore, and as detailed below, our clients control land which will enable the expansion of educational facilities in the town, further enhancing its suitability for growth. The potential for schemes to deliver additional educational capacity is highlighted as an important factor in considering the scope of towns and villages to grow and the ability of our clients to achieve this for Southam should be recognised in its acknowledgement of a location for further growth. 2.6 Our representations are accompanied by two site submissions for land on the western side of Southam which have previously been promoted through the preparation of the Stratford-on-Avon specific Site Allocations DPD; and the Scoping & Call for Sites Consultation for the South Warwickshire Local Plan undertaken in May 2021. Promoted Site(s) 2.7 Land controlled by Barwood Land extends to approximately 30ha and comprises two land parcels as follows: • Parcel 1 – Land South of Welsh Road West which could accommodate approximately 140 dwellings at 30dph or approximately 190 dwellings at 40dph; alongside a publicly accessible riverside park to the benefit of all residents in Southam; and • Parcel 2 – Land North of Welsh Road West which could accommodate approximately 280 dwellings at 30dph or approximately 375 dwellings at 40dph; together with associated landscaped open space. 2.8 The sites have been included in the Councils’ ‘List of Call for Sites Submissions December 2021’ under Site Ref: 453. 2.9 The land comprises an available, suitable and deliverable opportunity to accommodate housing needs (both market and affordable), in a sustainable location, within walking distance from the town centre. There are no landscape and/or technical constraints to bringing the land forward for development in the early stages of the plan period, and/or in helping to meet a shortfall in the five year supply of deliverable land. 2.10 For the avoidance of doubt, the development opportunity afforded by the land north and south of Welsh Road West can come forward independently of one another, or as a comprehensive opportunity to be masterplanned as a whole. 2.11 The land has inherent sustainability merits which make it suitable for residential development, and in our view represents a development opportunity providing a logical rounding off to the western edge of Southam on land north and/or south of Welsh Road West. 2.12 The development of the sites at Welsh Road West, Southam can make an important contribution towards achieving sustainable patterns of growth, especially with respect to the emerging aspirations relating to 20-minute neighbourhoods, particularly that associated with Southam (as referenced in Chapter 10 of the Regulation 18 document (Issue T1)). 2.13 The benefits of allocating the land parcels for housing development north and south of Welsh Road West, Southam, are manifest. The benefits are set out below. Overview 2.14 Informed by the technical work submitted in respect of landscaping, highways and sustainability matters, we consider that both parcels north and south of Welsh Road West are suitable for identification as a housing allocation in the emerging Local Plan. 2.15 The accompanying Vision Document explains how the land parcels could be developed as follows: Land South of Welsh Road West: • Approximately 140 - 190 dwellings • Access from Welsh Road West • Housing parcels well-related to the existing settlement • Landscape buffer to the west • Provision of a landscaped and publicly accessible riverside park; and enhanced pedestrian access Land North of Welsh Road West: • Approximately 280 - 375 dwellings • Access from Welsh Road West • Housing well-related to the existing settlement form (including the Taylor Wimpey development to the north), creating a new and defined edge to Southam • Potential to assist Southam College with future expansion plans and/or assist in managing conflicts between the school and the leisure centre • Direct pedestrian / cycle links to the College via the playing fields, negating the need for pupils to travel to school by car or along Welsh Road West • Landscape buffer to the west • Public open space; enhanced access 2.16 Collectively the two parcels could provide between c. 420 to 565 dwellings, to include a mix of house sizes and types as well as policy-compliant levels of affordable housing provision. 2.17 Where justified in accordance with paragraph 56 of the NPPF and Regulation 122(2) of the CIL Regulations 2010, financial contributions to be secured as part of a future planning permission would contribute towards improving services and facilities in the area; whilst the provision of a publicly accessible riverside park would enhance the setting of the town whilst also benefiting both existing and future residents in terms of providing a new opportunity for outdoor leisure and recreation. 2.18 Additional benefits include the provision of a new high-quality gateway into Southam from the west, opportunities to improve bus services and connectivity/sustainability for new and existing residents in this part of the town. Traffic calming measures can also be incorporated, with reduced speeds as well as improved walking/cycling links. 2.19 The site is located adjacent to the College for easy and sustainable access for education, with possible opportunities to support improvements in the education offer. For example, following direct discussions with the College, it is our understanding that the school aspires to having a new sixth form block and SEND provision, the development of which would require the loss of playing field space. In line with Sport England guidance, this would require re-provision. Our client owns all undeveloped land surrounding the College and is therefore in the unique position to be able to assist in facilitating these requirements. We would be very pleased to discuss these matters in further detail with the Local Plan team and Education Authority. 2.20 On the basis of the foregoing, and as a whole, the site represents a development opportunity that could deliver substantial and wide-ranging public benefits. 2.21 As set out in the introduction above, the land parcels are available as single development sites that can come forward independently of one another, or as a comprehensive opportunity to be masterplanned as a whole. However, we would stress that there are considerable public benefits associated with the comprehensive development. Highways and Sustainability 2.22 As set out in the accompanying Highways and Accessibility Technical Note prepared by Stantec, the land to the north and south of Welsh Road West adjoins the Southam built up area and represents one of the most sustainable locations in helping to meet the Plan area’s housing requirements as well as any unmet needs from neighbouring authorities including the cities of Birmingham and Coventry as explained below. 2.23 The sustainable and accessible location of the land is further acknowledged at paragraph 6.7.6 of the adopted Stratford-on-Avon Core Strategy which recognises Southam’s role as acting as a service centre for the eastern part of Stratford-on-Avon District together with the adjoining areas of Rugby District. It is therefore appropriate to ensure sufficient housing is delivered in Southam to safeguard its role as a service centre and maintain the viability and vitality of existing services consistent with paragraph 78 of the NPPF. 2.24 The whole plan area also has strong relationships with both the cities of Birmingham and Coventry through its inclusion of the housing market areas associated with both places. 2.25 Stantec has prepared a Technical Note in support of the merits and suitability of developing the land in the manner proposed having regard to highways, sustainability and access considerations. 2.26 The Technical Note includes a clear conclusion in relation to the suitability of developing the land parcels in the context of these considerations. 2.27 This includes the ability of the development to potentially fund an extended bus service that would further enhance the sustainability merits of the wider area, thus contributing to sustainable patterns of growth. It is also concluded that a safe means of access can be provided to the parcels and that they are within walking distance from local services and facilities. 2.28 Development on land north and/or south of Welsh Road West offers a unique opportunity to provide for housing growth adjoining Southam College. Not only would pupils from the scheme be able to walk to school, but the allocation of either of the plan parcels (north or south of Welsh Road West) provides opportunities to enable the expansion of the College (as discussed above). 2.29 Overall, development of the sites will result in significant sustainability benefits to the wider community (residents and College pupils), including, but not limited to, reduced traffic speeds through traffic calming, improved accessibility via enhanced foot and cycleway provision and extended and enhanced bus services. Flood/Drainage 2.30 As explained in the Vision Document, the land is within flood zone 1 and development for up to c. 565 dwellings can be satisfactorily achieved in relation to the proposed surface water and foul drainage strategy. Landscape General 2.31 Se set out in the Vision Document, the landscape-led approach to the scheme design has been informed by a thorough review of the landscape character of the sites and surrounding area. Land South of Welsh Road West: Masterplan Approach 2.32 The Masterplan approach has been informed by a thorough landscape appraisal. As a result, the illustrative layout provides for the retention of feature trees and hedgerows both within and on the boundaries of the site whilst also proposing new structural planting to provide for a significant amount of green infrastructure which helps to assimilate the development into the wider landscape character comprising dwellings interspersed with trees/landscaping. 2.33 The proposed development can be accommodated without material impact upon the character of the area or the visual amenity of public vantage points. 2.34 The peripheral areas around the edges of the residential areas have been designed to create a soft edge to the development, respecting the site’s edge of settlement location. 2.35 A wide green corridor is provided within the residential part of the development, which provides a quiet area of land. It incorporates the existing hedgerows and will be part of a sustainable urban drainage system. Buffer planting along the western boundaries will screen the site from the wider countryside to further to the west. 2.36 The Riverside Park is the principal area of publicly accessible open space, designed to be used by residents and the wider community. It is proposed as a large (circa 5ha) area of public open space with an area of wildflower meadow towards the western site boundary and an area of managed grassland for informal recreation. 2.37 The Riverside Park will also secure biodiversity enhancements. Ecological survey work undertaken to date has identified that within the site there are no habitats of county, regional, national or international nature conservation importance. 2.38 The Riverside Park could provide a range of public, recreational and ecological benefits, including as follows: 1. A large circa 5ha publicly accessible open space 2. A Riverside Park trail (to include provision of information boards along a riverside trail highlighting the wildlife of the Stowe Valley. They could also provide information relating to local heritage, the wetland and aquatic habitats, grasslands and meadows and orchard being provided within the park. The path will also take people past the Holy Well scheduled and listed monument beyond the south-eastern corner of the site. This recreational resource could also provide educational benefits linked to local schools) 3. Tree planting (planting of small groups and scattered parkland trees within the Riverside Park reflects the character of the Stowe Valley and the parkland at Stoney Thorpe and ties in with the local landscape. Whilst softening and filtering views towards the built edge, the trees are arranged so as to allow for the continued enjoyment of elevated views across the Stowe Valley and Stoney Thorpe Native species used to strengthen the landscape structure, soften the built edge and provide foraging for birds and bats) 4. A range of biodiversity enhancements 5. A trim trail/play area 6. Community orchard 7. Ponds and wetlands 2.39 Development of the Site provides a unique opportunity to secure a Riverside Park as a public asset for the town. 2.40 The proposed development will include measures to enhance the nature conservation interest of the site, through the creation of new areas of ‘habitat’. This will maintain and enhance opportunities for wildlife habitats in the local area. In addition, the existing trees and hedgerows are to be retained and enhanced with appropriate species, which will have further ecological benefits providing a greater mitigation of the potential visual impact of the scheme. 2.41 Overall, the landscape assessment of the proposed development concludes that the scheme will have a long-term moderate beneficial effect on the landscape character. This is in part due to the Riverside Park proposals which will enable the enhancement of degraded aspects of the landscape and provide a wide range of landscape, green infrastructure and recreational benefits. Land North of Welsh Road West: Masterplan Approach 2.42 Development within the eastern part of the site would relate to the existing settlement edge on the valley sides, tying-in with the Lilley Meadow development to the north. Containing development within the existing field pattern and reinforcing hedgerows and hedge tree planting would preserve the landscape structure. 2.43 As illustrated in the Vision Document, there would be opportunities to deliver substantial new woodland copse long with planting and tree belts to strengthen the field hedgerows on the slopes of the Itchen Valley. This reflects the published landscape guidelines for the area and would tie-in with woodland along the Itchen Valley to the west and south west of the Parcel. Landscape Summary: Both Parcels (North and South of Welsh Road West) 2.44 Some key design principles for the development of the Parcels to the west of Southam have been developed through the analysis of the landscape character and sensitivity. These have been incorporated into the Framework Masterplan for both Parcels and include the following: • Characteristic woodland copses and tree belts to boundaries to strengthen landscape structure, soften development edge and filter views; • Hedgerows retained through development parcels within green corridors, providing opportunities to connect through the site and biodiversity and landscape benefits; • Setting properties beyond a soft, well treed edge. Includes opportunities to soften the defined edge formed by properties above the Stowe Valley; • Creating a new, positive gateway at the entrance to Southam on Welsh Road West. Properties fronting the road, set-back beyond tree and hedgerow planting; and • Riverside Park wrapping around the edge of the development, connecting with existing recreation routes and forming a circular work to the south and west of Southam. Opportunities to manage the park and open space areas for biodiversity and wildlife gain whilst retaining the open aspect to the lower slopes of the Stowe and Itchen valleys. 2.45 As the Vision Document explains, both Parcels could be delivered together to provide a comprehensive development that respects the character of the settlement edge and incorporates a robust landscape structure providing enhancements to the character of the Itchen Valley and agricultural landscape to the west of Southam, whilst providing substantial areas of Green Infrastructure and open space managed for access and wildlife. 2.46 Development of the Parcels, both independently or together as part of a wider scheme offer opportunities to provide enhancements to the landscape structure and provision of new landscape features including woodland and trees in line with guidelines set out in the Warwickshire Landscape Character Assessment. 2.47 A substantial benefit of development of each of the parcels individually is that both offer the potential to provide large areas of land provided with public access as a riverside park, incorporating new links to the surrounding Public Rights of Way network and connecting with Southam and the wider countryside. In addition to the amenity benefits, the parks offer opportunities to be managed for wildlife delivering biodiversity enhancements. Heritage 2.48 As explained in the accompanying Archaeology & Heritage Assessment, designated heritage assets including listed buildings and Southam Conservation Area mostly lie at some distance from the proposed development and the site does not currently enhance their significance. Given level topography, intervening vegetation and built form, none of their settings would be adversely affected. 2.49 The Holy Well, which is both listed and scheduled, lies immediately south east of the site. Although this feature is of county significance, vegetation screens it from the site. Modern development lies close by and the open field system and meadows which would have formed its original setting have been enclosed. Nonetheless, the agricultural fields of the undeveloped valley of the River Stowe surrounding the well, including the south easternmost site field, do enhance the well’s historical significance. Much of the adjacent field would ideally be left as open space and the developed edge of the site should be landscaped. 2.50 The heritage context has informed the vision for the site, with the proposed development parcels respecting the setting of designated heritage assets. Benefits 2.51 Development of the land North and South of Welsh Road West for housing secures many benefits, including as follows: • Delivery of up to circa 565 dwellings (including policy-compliant affordable provision) • Potential to assist Southam College with future expansion plans and/or assist in managing conflicts between the school and the leisure centre • Aiming for provision of at least 10% Biodiversity Net Gain (with initial results showing a BNG in excess of 60% when using the DEFRA Metric) • Provision of high-quality areas of publicly accessible open space. • Provision of new and enhanced pedestrian and cycle links. • All new homes to be within walking and cycling distance from the town centre. • The potential to contribute towards an enhanced public bus service to serve the proposed development and existing homes in this part of Southam.

Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

Issue S7: Spatial Growth Options 3.49 The draft Local Plan identifies a number of options for delivering growth across the plan area. This includes the expansion of existing settlements alongside consideration of new settlements. 3.50 We do not consider that new settlements need to be included in the strategy, including on the basis that there are options to provide growth as sustainable extensions to existing settlements. 3.51 Given the clear benefits that growth at existing settlements, including Southam would provide for achievement of sustainable behaviours, including those associated with a 20 minute neighbourhood, it is considered that urban extensions should be the focus of the approach of the emerging Joint Plan. 3.52 Whilst the Sustainability Appraisal suggests that 20 minute neighbourhoods have been scaled to equate to an 800m walk or cycle ride which would then deliver around 2,000 dwellings at a town within the Joint Plan area (paragraphs E8 and E9), as detailed in the observations with respect to Southam, these broad areas have been defined so that each area adjoining the settlement includes the relevant facilities as a focus for the neighbourhood. It does not therefore take account of the existing opportunities which would arise by using existing facilities as the focus. This is illustrated by the current location of primary and secondary schools off Welsh Road West, Southam. For the reasons detailed, a smaller area should have been considered as a reasonable alternative taking account of these principles. 3.53 Such an approach would be reflective of that of other local authorities, as illustrated by the work by East Hampshire2. 3.54 East Hampshire has provisionally defined 20 minute neighbourhoods for its emerging Local Plan based upon the existing location of important shopping centres together with primary schools, albeit that they have applied a 1,200m buffer rather than 800m as currently envisaged in the Joint South Warwickshire Plan area. 3.55 East Hampshire’s Topic Paper on Settlement Areas3 explains in paragraph 3.13 the reasons for identifying a 1,200m buffer was due to: These results show accessibility based on 1,200m distances from primary schools, mainline railway stations and the town, district or local centres identified by Policy CP8 from the East Hampshire Joint Core Strategy. Initially, a 20-minute neighbourhood area based on 800m distances – this being a 20-minute round trip on foot – was investigated, but this was found to exclude many residential areas within the larger settlements (e.g. Alton, Whitehill & Bordon, Liphook, Four Marks). An alternative neighbourhood area based on 1,600m distances – being a 20-minute walk in one direction on foot – was also investigated, but this would imply a 40-minute round trip. This duration was considered to be excessive when determining potential accessibility by walking4. As such, a compromise position of using 1,200m distances to define a 20-minute neighbourhood has been applied. 3.56 Given the similarities with respect to existing settlement forms across the Joint Plan area, as illustrated in Southam where there are undeveloped areas within 800m of the centre and/or primary educational facilities, these should be the focus for growth. Further, reflecting the refined approach as envisaged in East Hampshire, an enlarged area of up to 1,200m should be considered and this then applied to Southam and other settlements across the Joint Plan Area. 3.57 Therefore, like East Hampshire, the achievability of existing settlements to accommodate growth within an appropriate 20 minute neighbourhood should be explored, with undeveloped areas within the buffers considered further (like our client’s land off Welsh Road West). 3.58 An initial illustration of the extent that existing areas of Southam are within a 20 minute neighbourhood based upon 800m and 1,200m buffers to the town centre and primary school is illustrated in Figure 4 below. This confirms the location of our client’s land off Welsh Road West within the buffers as drawn around the primary school. 2 https://www.easthants.gov.uk/media/7727/download?inline 3 https://www.easthants.gov.uk/media/7727/download?inline 4 The Government’s National Travel Survey data shows a sharp drop in the average number of trips per person per year by walking when the trip distance reaches 2 miles (i.e. c.3,200m, estimated as a 40-minute trip). Source: National Travel Survey 2020, Table NTS0308

3.60 Overall, and building upon our representations upon the previous Scoping and Call for Sites consultation (Representations dated June 2021), we endorse a hybrid of Growth Options 2, 3 and 4. 3.61 Should Option 2 be pursued, given the excellent level of bus service provision in Southam alongside its other sustainability credentials, this settlement must be included as a location for growth under this option. 3.62 Given the inherent suitability and sustainability advantages of Southam in terms of the settlement hierarchy, including for the reasons assessed in the SA, it is clearly a key candidate for growth when assessed against the potential options across the joint plan area. 3.63 At a Southam-centric level, our client’s site represents the key candidate site for growth at the settlement, including on the basis that it outperforms the potential alternatives in terms of its sustainability advantages. 3.64 Providing for additional housing allocations at Southam will benefit from embedded travel behaviours, which arise from co-locating and enhancing the existing 20 minute neighbourhoods which are already established for the town. These are therefore the focus for key activities associated with health, leisure, work, education and convenience shopping which are already available in Southam. Therefore, additional residents in and adjoining the town (including on land off Welsh Road West) will adhere to sustainable behaviours from initial occupation. This contrasts with that associated with new settlements, (towns and villages) where delivery of key facilities to promote and achieve 20 minute neighbourhoods will not arise until there are sufficient residents and/or workers to ensure the relevant service can be viably supported. 3.65 This is a key virtue which supports growth at Southam as a result of its existing access to a range of facilities for health, leisure, work, education and convenience shopping to achieve 20 minute neighbourhoods. 3.66 The Department of Transport document LTN 02/08 ‘Cycle Infrastructure Design’5 (section 2.2) explores typical cycle trip distances and confirms that “two out of every three personal trips are less than five miles in length – an achievable distance to cycle for most people, with many shorter journeys also suitable for walking. For school children, the opportunities are even greater: three quarters of children live within a 15 minute cycle ride of a secondary school, while more than 90% live within a 15 minute walk of a primary school”. This confirms the potential for longer trips by bicycle, which will include commuting to work alongside those to secondary education as outlined above. This therefore indicates that the geographical extent of the 20 minute neighbourhood will be enlarged from that envisaged by the Council. 3.67 Although the TCPA Guidance6 on 20 minute neighbourhoods (page 19) states “Not all neighbourhoods will include a full range of services or facilities accessible by foot, which is why it is important to provide high-quality cycling routes and public transport for longer journeys to other places”, these opportunities are available at Southam. Consequently, it is clearly an acceptable and appropriate location for growth. 3.68 Chapter 4 of the consultation document outlines a number of approaches to delivering growth across the plan area. Within these, the Sustainability Appraisal identifies “Option 2 – Sustainable Travel” as one of the best performing. Options 3 and 4 also perform well. Whilst the Bus accessibility research by the Councils confirms the quality of services available at Southam, this is not listed as one of the indicative settlements covered. This is a clear failure whereas it is referenced in other options. Given the earlier comments with respect to the appraisal of our client’s land off Welsh Road West together with the Council’s research on bus services, we confirm our support for a hybrid of options 2, 3 and 4 provided it includes Southam. 3.69 As noted in the draft Local Plan, Option 2 seeks to strengthen the existing bus services which is a benefit to both existing and future residents of the plan area. 3.70 As previously outlined, development of our client’s land on land off Welsh Road West, Southam for between 420 to 565 dwellings (including affordable) will make significant infrastructure contributions through CIL and other mechanisms which can contribute towards infrastructure in the district and wider Joint Plan Area. This could include improved accessibility via enhanced foot and cycleway provision and extended and enhanced bus services. 5 https://www.gov.uk/government/publications/cycle-infrastructure-design-ltn-120 6 https://tcpa.org.uk/resources/the-20-minute-neighbourhood/

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

Site Context To support the promotion of Bellway’s Sites, a Vision Document (May 2021) has been submitted with these representations. As stated in our response to the SWLP consultation below, we consider that Long Itchington should be identified for growth given its location on a key transport route, the range of shops, services and facilities provided and that it is one of the few sustainable settlements that is not located within the Green Belt, AONB or Special Landscape Area. These designations are a key determining consideration when spatially planning for growth, where paragraph 141 of the National Planning Policy Framework (‘NPPF’) makes clear that all other reasonable options outside of the Green Belt have been examined before exceptional circumstances apply. Paragraph 177 of the NPPF sets out a similar sequential approach to protecting the AONB. When allocating sites within Long Itchington, a flexible approach can be taken to the delivery of Bellway’s sites determined by the approach taken in the plan and the number of dwellings directed to the sustainable settlement. The options for delivery of the site and the scale of opportunity are set out in the submitted Vision Document and summarised below: • Option 1 - Northern site only (SHLAA Long.9)- Circa 45 – 55 dwellings (30 – 35dph). • Option 2 – Northern and Southern sites (SHLAA Long.9 and Long.18) – Circa 80 – 100 dwellings (30 – 35dph). • Option 3 – Northern and Southern sites as well as land to the south of the canal (SHLAA Long.9, Long.18 and Long.21)– 100+ dwellings as well as potential community uses and / or school if required. The key benefits of allocating Bellway’s sites for residential development within Long Itchington are considered to be as follows: - The land is immediately adjacent to the settlement boundary and is surrounded by existing development along the southern and western boundaries. Therefore it is considered to make a logical extension to Long Itchington. - The land is directly adjacent to Southam Road which connects the site via public transport to Leamington Spa, Rugby and Daventry. - Enhanced pedestrian connections between the site and village centre could be provided. - Affordable housing in accordance with policy requirements could be provided. - Public open space, tree planting and landscaping will be provided within the site and along the retain Public Right of Way and canal. - Enhancements to the canal towpath could be delivered. - Attenuation and SUDS features could be provided for surface water management and biodiversity enhancements. - Biodiversity Net Gain could be delivered across the sites. - Additional development around the village could help support local businesses through increased patronage. Bellway will work with Stratford-on-Avon District Council (‘SADC’), Long Itchington Parish Council and the local community through the local plan process to develop a scheme which assists in meeting the needs of the local community, District and wider Housing Market Areas.

Q-S1: Please select the option which is most appropriate for South Warwickshire (Green and Blue Corridors) Bellway support Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. It is considered that the Councils should identify the green and blue infrastructure assets they seek to protect and enhance in the first instance and then identify their preferred development options. This will ensure that the growth strategy is not unduly constrained at a later date. Q-S2: Please select all options which are appropriate for South Warwickshire (Intensification) Bellway supports Option S2c: Do not have a policy which encourages intensification. Given the scale of the District and the range of urban and rural areas as well as the SWLP being a part 1 strategic plan, we consider that the SWLP should not apply a blanket approach to densities and intensification at this stage. Chapter 11 of the NPPF encourages effective use of land but there are a number of criteria that must be taken into account when considering densities including the need for a certain type of housing, local market conditions, viability and prevailing character of an area (paragraph 124). Policy wording within the SWLP could ‘encourage’ intensification on sites in certain locations but the final density of a site should be agreed on a site by site basis. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Bellway supports Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Paragraph 119 of the NPPF is clear that planning policies should make as much use as possible of previously developed land. Furthermore, paragraph 120 states that planning policies should give substantial weight to the value of using suitable brownfield land. However, although significant weight is placed on the development of brownfield land, the NPPF (paragraph 11) is also clear that “plans should promote a sustainable pattern of development”. Therefore it is important that only brownfield sites in sustainable locations are prioritised. Brownfield land in an unsustainable location (not adjacent to an existing settlement) should not be allocated above a greenfield site which is adjacent to an existing sustainable settlement such as Long Itchington. Notwithstanding the above, the Urban Capacity Study (October 2022) is clear that there will not be enough urban sites to meet South Warwickshire’s housing needs across the plan period. Greenfield sites will be required and the prioritisation of greenfield or brownfield sites should only be based on realistic assumptions on when they are likely to be delivered. For example, a greenfield site with a housebuilder promoting it is likely to be able to be delivered before a brownfield site with an existing use still occupying the site / buildings. Q-S5.2: Do you think new settlements should be part of the overall strategy? No - Bellway consider that future growth should be directed to existing settlements as they are already well established and offer immediate opportunities to deliver development. Should a new settlement be pursued then significant evidence should be prepared to assess the level of infrastructure required to deliver it and realistic assumptions on its delivery should be made. The SWLP proposed plan period may also require extending as the NPPF (paragraph 22) encourages plans to have at least a 30 year plan period where new settlements are proposed. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. and Q-S5.4: If not, what approach would you take? As set out in our response to Q-S5.2, Bellway consider that existing settlements should be the focus of growth. Should any new stations or significant development around new stations be proposed then sufficient evidence should be prepared around costs and delivery of housing. Issue S6 (A review of Green Belt boundaries) – no specific question included in the SWLP. There is no specific question relating to Issue S6 in the SWLP which we assume is an error given every other issue has a question attached to it. There is significant national policy protecting the loss of Green Belt land (NPPF Chapter 13) and exceptional circumstances are required to justify amendments to Green Belt boundaries within a plan (NPPF paragraph 140). In light of this, Bellway considers that non-Green Belt locations should be identified for growth in the first instance. There are suitable, available and deliverable sites adjacent to existing sustainable settlements outside of the Green Belt, such as Long Itchington, that should be considered for growth before any significant Green Belt release. Q-S9: Please select the option which is most appropriate for South Warwickshire (Settlement Boundaries and Infill Development) Bellway supports Option S9b - review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries Bellway considers that settlement boundaries should be reviewed if there are any allocations proposed adjacent to them.

I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful.There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.

I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. - Any other comments: I am specifically opposed to development of land in the greenbelt areas in/around Weston under Wetherley and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt

- Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas.Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt

All settlement boundaries should be reviewed as part of the SWLP, this will ensure consistencies of approach between Stratford-upon-Avon and Warwick Districts.

Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were mitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt

South Warwickshire’s Development Requirements 3.2 We agree with the premise that the Local Plan’s primary role is to promote a sustainable pattern of development that seeks to meet the needs of South Warwickshire, align growth and infrastructure, improve the environment, mitigate climate change and adapt to its effects. 3.3 This inevitably requires a number of considerations to be balanced alongside and together in order to arrive at an overall strategy and plan. This will include a degree of prioritisation and choice. It is symptomatic of this stage of the plan making process that the overall strategy is dependent on the selection of individual sites and vice versa; in other words this is an iterative process. 3.4 However, this needs to be guided by high level principles; a commitment at the outset to provide sufficient land for the overall amount of new development that is forecast, a spatial strategy that is aimed at achieving the most sustainable pattern of development; and avoiding and minimizing unacceptable environmental effects whilst achieving environmental benefits wherever possible. 3.5 Our representations have been prepared in this context, albeit we comment specifically in relation to the scale of housing required in response to Matter 5. Development Distribution Strategy for South Warwickshire 3.6 A fundamental part of the Local Plan will be to ensure that the future development requirements are distributed in a manner that achieves the most sustainable pattern of development. This concept has different interpretations and requires a balanced approach, but the underlying premise of situating new development at and adjacent to the main urban areas must be the starting point in order to capitalize to the fullest extent on the sustainable pattern of development this will achieve. 3.7 It is an unavoidable fact that the main settlements in the plan area – Stratford-upon-Avon, Leamington Spa, Warwick – are those locations that have services and facilities commensurate with their role and function. In hierarchical terms, these settlements are pre-eminent locations. This is borne out by the evidence of the Spatial Options background paper and the Sustainability Appraisal. In this regard, only Stratford-upon-Avon features as a settlement consistent with each of the Spatial Options. 3.8 It is evident that the favored spatial options are those that afford a priority to accessibility to services and facilities, enabling movement by active travel and public transport, and supporting economic growth, whilst protecting areas with important environmental attributes. In effect this points towards a blended strategy, or the hybrid strategy referred to in the consultation document. 3.9 The consultation document refers to this approach as providing a balance of growth at existing main settlements, some growth at new settlement scale on the rail lines, and more modest growth in smaller settlements, which can contribute to enhancing the viability of village centres and provide affordable housing. 3.10 In developing this blended spatial strategy to guide the location of new development, it is unarguable that Stratford-upon-Avon will be a cornerstone of whatever strategy is chosen. In this regard, the fundamental objective is to ensure Stratford-upon-Avon best contributes to the overall strategy. To achieve this requires the overall contribution of development land at Stratford-upon-Avon to be the building block in the first instance so that, as a suitable location, it can maximise its influence on the blended strategy that effectively follows. 3.11 This approach would have the following benefits: - Align with the objective of reducing carbon emissions; the greater the degree of concentration at main settlements the lesser the carbon emissions (Figure 2 refers); - Capitalise on the availability of services and facilities and the promotion of active travel; - Contribute to the vitality and viability of the town centre; - Support labour supply in the “Core Opportunity Area” in the context of an ageing population overall; - Maintain the West Midlands Green Belt in the north of the plan area; - Limit development in the Area of Outstanding Natural Beauty in the south of the Plan area - Avoid the negative effects of the dispersal strategy illustrated in the Sustainability Appraisal (Table 7.1 refers) 3.12 A strategy that promotes large scale development adjacent to Stratford-upon-Avon’s existing urban area could also achieve a commensurate scale of nature based solutions and investment in renewable and low carbon energy generation to mitigate the effects of and adapt to climate change. 3.13 Whilst the blended strategy described above refers to new settlements, as a matter of approach, this can only represent part of a development strategy in the longer term; experience from elsewhere in the country suggests lead in times from policy formulation to development and build out being a great many years. As such, a new settlement cannot represent a means of meeting short and medium term needs. This Option would inevitably need to be complementary to development at existing settlements which are suitable in the first instance as a matter of principle. Direction of growth at Stratford-upon-Avon – the South East of the town 3.14 In the preceding paragraphs we have set out how the spatial strategy should afford a role to Stratford-upon-Avon as a focus for new development. Although there is no consultation question in relation to directions of growth at Stratford-upon-Avon, the evidence base is particularly instructive as to the advantages of development to the south-east of the town. 3.15 The Evaluation of Broad Locations in the Sustainability Appraisal alights upon this location as the best performing of those around the town. It is the most suitable in terms: - Planning for anticipated levels of climate change (i.e., flood risk) - Protecting, enhancing and managing the quality and character of landscapes and townscapes; - Mitigating adverse impacts from existing air, water, soil and noise pollution and avoiding generating further pollution; and 3.16 The graphic overleaf illustrates the inescapable relative overall and “strong” performance of this location. [see submission document for graphic] Accessibility and Permeability 3.17 The Settlement Analysis similarity affords a positive view of south east of the town. In terms of permeability or conversely the absence of barriers to integration, none of the town’s urban edges are Categorised as A, so whilst areas 6, 7, 8 and 9 in the south east of the Town, which correspond to Trinity Way and Banbury Road, are Categorised as B, this is the highest ranking across the settlement as a whole. 3.18 In conjunction with a permeable edge, three of these four locations score the highest in terms of accessibility to services and facilities within 800m. Whilst a small number of locations exhibit this degree of accessibility, none of the other urban edges around the Town achieve a combination score of B and 5 together. In these terms, areas 7, 8 and 9 in the south east area are especially well related, and perform better than the area of land (6) identified as a proposed allocation in the Stratford-on-Avon Site Allocations DPD. Heritage 3.19 Of note from the written analysis is that the eastern area is said to have heritage constraints that reduce its performance for this environmental consideration. However, what is referenced is East Tiddington Roman Settlement which is some distance away from the likely development areas centred on Trinity Way and Banbury Road, and would not represent a genuine constraint to new development in those locations. 3.20 The Heritage Sensitivity Assessment records on page 198 the following in relation to the south east part of the town: This area runs from the southern edge of Tiddington round to the eastern side of Shipston Road. Extensive modern development on the western side means that the historic core is less sensitive to change in this area. A single group of Listed Buildings are located at Alveston Hill Farm and their rural setting would need to be considered in any development. However, this area may be able to accommodate development. 3.21 In the RAG analysis that follows the following points are made alongside a green score: The south east area only contains a single group of designated assets and does not impinge on any of the conservation area boundaries. The rural setting of these designated assets will need to be considered in any planning proposals. This area may be able to accommodate development.” 3.22 The diagrams on page 201 and 202 of the Heritage Sensitivity Assessment illustrate the comparative extent of designated and undesignated heritage assets around the town, with relatively few located in the south east. 3.23 For all of these reasons a considered view of the south eastern area indicates that cultural heritage is not a constraint to new development in the location. Landscape 3.24 We note that a Landscape Assessment for the plan area as a whole is being prepared and is not available at the present time. We expect such an assessment to acknowledge that land south of Trinity Way is not designated for its landscape or historic importance; it does not fall within a Special Landscape Area, or Conservation Area and; it does not form the setting of any listed buildings. 3.25 The character of Stratford-upon-Avon, to the south east of the town, is suburban, comprising post war housing with some modern infill. The interface between the urban and rural area is typically abrupt, with existing housing turning its back to Trinity Way behind hedge and fenced boundaries. Whilst the Site itself is not unattractive, it is not considered to be remarkable or exceptional. The field structure is poorly defined, the edge of the town exerts an urbanising influence over the area, and its intensive arable uses result in a site with a medium aesthetic appeal and/or amenity value. Green Belt 3.26 We recognise that certain of the assessment work has been undertaken with a “policy off” position applied to the Green Belt designation that extends long the northern edge of the town. However, Green Belt policy in the NPPF only permits the amendment of the Green Belt where exceptional circumstances exist (para 140 refers). For exceptional circumstances to be justified, it is necessary to examine fully all other options for meeting the identified need for development. This requires an assessment of Green Belt and non-Green Belt locations. 3.27 In this instance, development to the south-east of the town can be seen to perform better than Green Belt locations and, on this basis, the exceptional circumstances would not be justified. In the context of the great importance afforded to Green Belt, locations subject to that designation would need to exhibit characteristics that are materially better than non Green Belt locations in order to be preferred as future development locations. That plainly is not the case at Stratford-upon-Avon and those non Green Belt locations should form the identified allocations in the first instance.

Thank you for the opportunity to submit representations to the Issues and Options stage of the South Warwickshire Local Plan Part 1. Stoford have prepared these representations following discussions with the Birmingham & Solihull Rugby Football Club, and adjoining landowners, covering some 50ha of land to the south east of Junction 3, M42. The land is on the edge of Stratford District’s boundary with Redditch/Bromsgrove and is in part bound by the A435 which is a key investment corridor for the neighbouring Districts and one of only two locations where the M42 can be accessed from within South Warwickshire. Stoford are supportive of the decision by the two Council’s to prepare a Joint Local Plan and see this as an opportunity for the key infrastructure linkages that serve both Districts, being maximised and underpinning a spatial strategy. The M42/M40 and rail connectivity within the Districts’ offers the potential to be the basis for some of the Local Plan’s key strategic employment sites. Stoford participated in the earlier stakeholder events held in 2022, and it was interesting and helpful to undertake the exercise of considering the spatial distribution of growth, and to see how this has now informed the five spatial options presented in the consultation material, and the consideration of new settlements. Clearly the challenge for the Local Plan is accommodating growth, but also considering how the Green Belt will interplay with that. The majority of the railway stations for example – that are crucial to achieving active travel and addressing climate change through non motorised single occupancy trips, are located within the Green Belt, as are junctions 3 and 3a of the M2, and junctions 16 and land west of 15 of the M40. In our view, in order to maximise the opportunities presented by the M42 and connections from there to the wider motorway network, and to encourage increased commuting by rail, development sites will also be required to be released from the Green Belt within South Warwickshire in addition to non-Green Belt sites adjoining existing towns/settlements. New Settlements Issue S5 within the consultation material concerns the potential for new settlements and the contribution these can make towards the necessary growth required over the Plan period. The adopted Stratford Core Strategy included two new settlements, and these have since commenced development and are positively contributing towards the delivery of new homes, and jobs within Stratford District. Gaydon Lighthorne Heath was one of these, located on the edge of the District and adjacent to the M40. The location of our promotion site at J3 of the M42 is similar in nature – being located close to a motorway, on the edge of the District – but is equally in our view more attractive as an option for development, given the proximity of local rail connections. Our enclosed promotion document includes circa 50ha of land that Stoford consider could be developed for strategic employment uses. Adjacent land could contribute towards a new settlement – noting the potential option A1, within Figure 12 of the consultation material that identifies a possible location for such a settlement being between the areas of Earlswood and Henley in Arden. Stoford agree with question S5.2 of the consultation material, that new settlements should be part of the overall strategy and it is important these are linked with new strategic employment land too, in order to maximise the potential for these settlements to be sustainable and reduces the need for travel. Stoford also support the potential to look at rail corridors and the role that they can have in supporting potential locations for development. Where rail corridors (and stations) are located alongside other key infrastructure such as motorways and A roads, there are opportunities for these locations to be explored for sustainable development. Stoford advocate that land to the southeast of junction 3, M42 is such a location. The attractiveness of this location for commercial development, particularly industrial and logistics is unique for this stretch of the M42 within Stratford, given it is the only junction with this motorway within South Warwickshire. Green Belt Boundaries We note that Issue S6 introduces the potential for a Green Belt review. We agree with the commentary on page 56 of the consultation material that states ‘In identifying locations for development across South Warwickshire including those currently within the Green Belt, the need to address climate change and deliver a sustainable pattern of development is a critical factor.’ We agree that when determining the spatial strategy for South Warwickshire that the most sustainable strategy should include options that release land from the Green Belt, where that land is well connected with infrastructure and has the potential to deliver jobs, and potentially homes, with travel options that can be non-motorised.