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

Q-S1 – Please select the strategic green and blue infrastructure option which is most appropriate for South Warwickshire We fully support the Local Plan including policies on the provision of strategic blue and green infrastructure. However, the preparation of the Plan should not be delayed by the production of the Local Nature Recovery Strategy. In addition, the Local Nature Recovery Strategy will not be tested in the same way development plan policies will through the examination process. It is, therefore, our view that the preferred approach should be Policy S1a, identification of strategic green and blue corridors in the SWLP in advance of the preparation of a Local Nature Recovery Strategy, so that this policy can be brought forward in a timely manner and tested through the examination process. It is noted that page 34 of the Plan advises that it is anticipated that the Part 1 Plan will set out the development principles and associated blue and green infrastructure required for the broad locations that are identified, and the Part 2 Plan will provide more details on the strategic locations and also set out the development principles and details on the non-strategic locations identified for growth. As detailed elsewhere within our representations, we object to the preparation of a two part plan. However, if this is ultimately the preferred approach the Part 1 Plan should not defer to the Part 2 Plan for additional details on the strategic locations for growth as it may delay their delivery. The policy guidance for the strategic allocations contained within the Part 1 Plan should be sufficient for them to be brought forward immediately, without having to delay the preparation of applications until the completion of the Part 2 Plan. The Part 1 Plan will need to make it clear that the strategic sites can be brought forward for development upon adoption of the Part 1 Plan in order to ensure that there is a continue supply of housing and employment land. QS2 – Please select the intensification options which are most appropriate of the South Warwickshire Whilst we fully support making the best use of available sites, the plan needs to be realistic in terms of the ability of an intensification policy to deliver additional development. Page 39 of the Draft Plan advises that intensification can be achieved in a number of ways. We comment on these options as set out below: • Conversion of upper floors of buildings to residential use We have no objection to this proposal, however, permitted development rights and positive planning policies in general have facilitated in bringing the upper floors of buildings back into residential use for a number of years. The inclusion of a policy supporting such proposals is unlikely to result in any significant increase in dwellings. • Additional storeys and buildings This is an unreliable source of housing. There needs to be an understanding of whether buildings are structurally capable and designed in such a way to allow additional floors added to them. Also, there may be design implications and visual impact issues associated with the creation of additional stories. There have been permitted development rights in place for a number of years that allow for the development of two extra stories of accommodation on certain buildings, meaning that such schemes can already come forward in a number of instances. This is unlikely to be a significant source of supply. • Re-use of empty homes When a home is empty it is often for good reason. For example, an elderly person going into care accommodation with the hope that they may return home, or general churn in the housing stock. Furthermore, re-using an empty home is not a “net” source of supply unless once the property became vacant it was recorded in the housing land supply calculations as a loss of a dwelling, which we very much doubt it will have been. There is the potential for there to be double counting from this source of supply. • Infill in residential areas There are positive policies in place for filling the gaps in street frontage and developing disused garage blocks within the adopted Local Plans. A policy supporting infill development is unlikely to result in additional sites coming forward beyond those that are already available. We have significant concerns with the suggestion that car parks could be developed for housing. A car parking strategy would need to be prepared in order to establish whether these car parks are required, as removing car parks could impact on local shops and services where customers use the car parks, or reducing car parking space available in residential areas resulting in additional on street parking. In addition, all of these sources of supply would, in effect, be windfall sites. They are not a new source of supply that will be boosted by the inclusion of a policy in the SWLP. In terms of new developments there needs to be a realistic consideration of the net developable areas and densities that can be achieved. In order to secure high quality design, new developments will need to provide on site open space, green infrastructure and have the ability to satisfy biodiversity net gain requirements This is likely to impact upon the net to growth land ratio available. Indeed, if it is assumed that 40% of greenfield sites will be required for green infrastructure and biodiversity net gain offsetting, this is likely to reduce the total net developable area to around 50% of the gross when infrastructure requirements are considered. Indeed, we note that the plan’s ecological policies suggest that 50% of sites may need to be set aside for green and blue infrastructure (Option C9.1a). Furthermore, we expect the Plan will require a variety of house types to come forward, ranging from bungalows and apartments, to larger 3, 4 + bed properties. Sufficient car parking must be provided within residential schemes in order to try to avoid on street car parking. There will also be areas within the Plan, such as on the edge of settlements and villages, where densities will have to reflect the character of the surrounding area in order to provide a high quality design. In summary, whilst we have no objection to the inclusion of an intensification policy, it is our view that it is highly unlikely to result in significant additional development and should not be treated as a new source of housing land supply beyond that expected from windfalls. Q-S4.1 – Do you think the growth of some of our existing settlements should be part of the overall strategy? Yes. The growth of the existing settlements should be a key part of the growth strategy of the Plan. The SWLP’s housing and employment requirement should be delivered principally through the expansion of existing towns and settlements. The level of development directed to each of the settlements within the plan area should be influenced by a series of factors. This includes the level of service provision within each of the subject towns and the nature of the development opportunities being proposed in these locations. For example, expanding the Long Marston Airfield new settlement should be a key objective of the plan. Long Marston Airfield is relatively small for a new settlement. The Draft Plan advises that new settlements should provide 6,000 dwellings. Long Marston Airfield is allocated for and has planning permission for 3,500 dwelling alongside employment land and supporting infrastructure. Increasing its size will supports its school, services and facilities. It will increase the size of the workforce available to support the approved employment land. Further details on this matter can be found in our Call for Sites submission. Q-S5.2 – Do you think the new settlements should be part of the overall strategy? The development of new settlements can be an effective way of delivering a significant amount of housing and supporting infrastructure through the plan making process. However, new settlements that require a complete infrastructure package will, in all likelihood, take at least 5 to 6 years from the allocation plan to start to deliver housing. They must, therefore, be supplemented by smaller allocations. In terms of infrastructure thresholds, it is noted that it is advised that 6,000 dwellings is the minimum size of a new settlement. As referred to above, whilst Long Marston Airfield is identified as a new Settlement by the adopted Stratford on Avon Core Strategy it is 3,500 dwellings in size. Directing additional development to Long Marston would bolster its role as a new settlement, with additional footfall supporting its schools, services and facilities and helping to deliver critical infrastructure.

Issue S1 (Green and Blue Corridors) Q-S1: 3.10 Catesby Estates supports the concept in the Consultation Document that the SWLP will take a proactive approach and seek to identify its own ‘Green Corridors’ across the plan area in advance of the Local Nature Recovery Strategy, in line with Option S1a. The Consultation Document suggests that this would allow Strategic Green and Blue Corridors to ‘inform the growth strategy.’ Whilst this is agreed, determining Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced should ensure that the corridors and growth strategy do not conflict with one another. Furthermore, these corridors within the Local Plan also ensures that they are appropriately consulted upon against the statutory tests for plan-making. 3.11 Catesby Estates reserves the right to comment upon any Strategic Green and Blue Corridors identified within future iterations of the Plan. Any such corridors should be based on proportionate evidence, including around delivery. Q-S3.2 3.15 Given the clear deficiency in the supply of brownfield land identified above in response to Question S3.1, Catesby Estates considers Option S3.c should be followed. This is not to say that we do not support the redevelopment of brownfield land, but even on the basis of the theoretical exercise, brownfield land will not supply even half of the housing requirement and so the focus should be on identifying the right sites in the most sustainable locations, importantly those which are deliverable and can meet the ful l policy requirements including affordable housing. Issue S4 (Growth of Existing Settlements) Q-S4.1 3.16 Growth at existing settlements is crucial to ensure their long-term sustainability, vitality and viability of local services such as shops, public houses and sports clubs. This includes settlements of all sizes, ensuring that growth is proportionate to the scale of the existing settlement, whilst also considering its accessibility to other nearby service centres, for higher order services and employment opportunities. Issue S5: The potential for new settlement (s) Q-S5.2 3.21 Catesby Estates recognises the benefits of delivering new settlements as part of an overall growth strategy. However, we also acknowledge the implications this may have for delivery and the importance of a mixture of sites to ensure flexibility of supply, particularly within the early years of the Plan. Growth at existing settlements, including both main towns and large villages, to allow for coherent and balanced development to occur throughout the Districts. 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? 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? 3.34 Limit of 10 dwellings per site / A higher limit is appropriate / A lower limit is appropriate 3.35 Notwithstanding that Tiddington should be a part of the Growth Strategy as set out above, Catesby Estates does not support a threshold approach as this would serve to restrict windfall growth which may otherwise be sustainable and necessary to meet local and wider needs. In this regard, we consider each development should be considered on its own merits. Q-S9 Please select the option which is most appropriate for South Warwickshire 3.36 Option S9a – Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. 3.37 Option S9b – Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 3.38 Catesby Estates does not support either of these approaches. The purpose of the Part 1 Plan is stated as to set out the overall strategy for the pattern and scale of growth, which will include allocating sites for development. Some of these sites will be adjacent to existing settlements and it would accordingly be prudent to amend existing settlement boundaries to accommodate these allocations (otherwise they would be considered to be ‘open countryside’ in planning terms). 3.39 Any further allocations made through Part 2 Plans would then provide a similar opportunity to make further modifications to settlement boundaries as necessary at that stage. 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. 3.41 Catesby Estates wishes to reiterate that a balanced approach should be achieved when looking at the development distribution strategy for South Warwickshire. It is apparent that n ot all of South Warwickshire’s housing need, (in addition to unmet needs of neighbouring authorities), can be met within existing urban areas. Therefore, there is clear need to develop greenfield sites outside of these areas, as well as a need to distribute growth to ensure the vitality of settlements such as Tiddington. 3.42 Nonetheless, in terms of the distribution of this growth, not one individual factor as set out within the Options should be undertaken as an isolated approach. A joint up approach, taking into account infrastructure including public transport access and availability, employment locations, facilities and census information should be considered, but overall a wider balanced approach should be considered. 3.43 Therefore, a wider balanced approach should be proceeded with, to ensure a variety of development comes forward. This would allow the greatest flexibility of supply throughout the plan period.

I am a resident of Henley in Arden & I would submit the following comments regarding the proposed SWLP. ·I fail to see how the SWLP proposal will align with the Levelling Up & Regeneration Bill & the 25 Year Environment Plan. Specific references are made to greater protection of green belt, emphasis on utilizing brownfield sites as a priority, abolition of top-down housing figures, emphasis on localism etc along with the ceasing of land banking. ·Henley lies between larger urban developments. The green belt surrounding Henley serves to prevent urban sprawl. ·The SWLP has been partly developed to take into account the overspill from Birmingham & the Black Country. However, on the BBC Politics Live program broadcast last week, Kevin McFadden, MP Wolverhampton South, stated that he was against the usage of Green Belt. He cited that there was ample Brown Fields in his own constituency that could be used for development before the use of Green Field sites. There are also numerous MP’s from all parties who oppose Green Belt development, as indicated by parliamentary HANSARD records. There are 1.2M homes in England that could be built upon Brownfield sites. ·The proposed development is inconsistent with commitments made in the existing planning policies. ·There is only one road through Henley. It servers as a main thoroughfare, parking spaces (some of which require reversing into the passing traffic) are on both sides of the road and are fully utilised. Delivery vehicles to the high street shops, along with Council refuse lorries are often forced to double park, restricting traffic flow to single lane. For safety reasons, traffic calming measures are planned to be tried this year. In addition the area is surrounded by extremely narrow country lanes which would not cope with additional volumes of traffic. Therefore, I fail to see how the existing road networks could cope with the substantial increase in traffic, which would be associated with the proposed housing & mixed development in the SWLP proposal. ·The above does not take into consideration the impact additional traffic & associated congestion would have on road safety & just as importantly air quality issues. ·The SWLP implies that there are good transport links in Henley. This is plainly not the case. There are only twelve scheduled bus services per day between Birmingham & Stratford. There are no bus services that travel East to West. The rail link between Stratford & Birmingham is scheduled to run hourly. The journey time from Henley to Birmingham is forty minutes. There are also limited parking spaces at Henley station. The existing travel services are not sufficient to meet the needs of the existing population of Henley. ·Infrastructure in the Henley district is antiquated. The mains water supply in the outlying areas is continually having to be ‘patched up’. There are no mains gas or sewage connections in the outlying areas. ·What provisions will be made to address the possibility of flooding? It is a fact that Henley town is susceptible to flooding. What is not so well known is that some of the outlying areas are also susceptible to flooding. The fields to the South East of Henley act as ‘run off’ areas. Once the fields are fully saturated, the surrounding Lanes are liable to flooding. What impact will proposed development have on flood plains? ·From available data the population of Henley grew by 10% between 2000 & 2015. However, there has been no investment in infrastructure for decades. The lower estimate of the plan lists 500 new homes. This must surely more than double the existing population of Henley. Again, begs the question as to why the SDLP does not address infrastructure. There is zero faith in developers addressing / fulfilling infrastructure commitments. My biggest concern is that the SWLP proposal, even at the lower estimate of growth, will completely destroy the character of an historic town. I fully accept that growth is required & there is a genuine need for affordable housing. However, surely this can be achieved in a sensible, pragmatic approach that takes into consideration the environment, existing infrastructure, heritage, tourism & most importantly ‘localism’. The current SWLP growth proposal is totally out of balance with the existing Town, community & environment. Please let the local communities have a greater input into the decision making when reviewing the SWLP. I am sure you will find that its a lot less about NIMBYISM & and more about developing communities & services that reflect local requirements, both current & future.

LAND SOUTH OF MAIN STREET, TIDDINGTON Site Description and Context Site Description 9.1 The Site measures approximately 16.44 hectares in size and is located alongside the existing eastern boundary of Tiddington Village, to the south of Main Street. It comprises several agricultural fields. The recently constructed Hayfield Homes development lies adjacent to the to Tiddington Community Centre to the north of the Site situated off Sid Countery Road. A draft SAP allocation (TIDD.A – South of Sid Courtney Road) for 24 new dwellings is located between our Client’s Site and the Hayfield Homes development. The SHLAA reference for this draft allocation is TIDD.11. 9.2 The Site is bound by agricultural land to the south and east. A recently built out residential development for 60 dwellings known as Birnam Mews adjoins the western boundary of the Site (reference 15/02057/OUT, reserved matters approval 18/01964/REM), developed by L&Q Estates. 9.3 Access to the Site is proposed off Main Street to the north. To create an access, 25 metres of 18 allotment plots operated by the Alveston and Tiddington Allotments and Gardens Association (ATAGA) from the Coventry Diocese will be utilised. To mitigate this, 20 new plots and associated improvements will be provided by Coventry Diocese to the rear of the existing plots. This proposal has been agreed with ATAGA and works to implement the new allotments are due to commence in March 2023. 9.4 The Site is relatively flat and is understood to be largely free of any significant physical and environmental constraints to future development. The Site is entirely within Flood Zone 1. Context 9.5 The Site is located to the east of Tiddington, approximately 2km to the east of Stratford-upon-Avon. As such, the Site is well placed in relation to a wide range of existing facilities, services, and amenities, including but not limited to Stratford-upon-Avon town centre, convenience stores, restaurants, primary schools, secondary schools, post office, and medical facilities. The Local Facilities and Services Analysis (Ref. Figure 2) on pages 10 and 11 of the accompanying Vision Document (Appendix 2) sets out the facilities and amenities within a 3km radius of the Site. 9.6 To the east, Wellesbourne is approximately 5km direct distance away. This offers local retail and communities services and amenities in addition to education facilities and employment opportunities, including employment linked to Wellesbourne Airfield. 9.7 The Site benefits from being well located with regards transport connectivity. There are existing bus stops on Main Street to the north of the Site adjacent to Carters Lane. This provides access to the number 15 service operated by Stagecoach Midlands which links Leamington Spa, Warwick, and Stratford-upon-Avon. The service operates daily Monday to Sunday with buses departing approximately every hour between 6am to 9.30pm. 9.8 Stratford-upon-Avon railway station is located approximately 6km to the west of the Site in a direct line. The station provides regular connections to Birmingham (2 trains per hour) and London via Leamington Spa (1 train per 2 hours) on weekdays and Saturdays during off -peak hours. There is a slightly reduced service on Sundays and Bank Holidays. 9.9 A Public Right of Way (PRoW)runs though the Site in a northwest to southeast direction, connecting Main Street to Pimlico Lane. There are opportunities to link up the PRoW route with the proposed development and to enhance pedestrian and cycle access through the Site. 9.10 As set out in this section, this demonstrates that there are a wide range of accessible sustainable transport options directly from the Site to local and national destinations. Constraints and Opportunities 9.11 The Site is not located in the Green Belt. The Site is located adjacent to Tiddington and the built up area. Tiddington is a Local Service Village in the Settlement Hierarchy in the Stratford-on-Avon Core Strategy (adopted July 2016), scoring 11 out of a possible 12 points in terms of facilities available in the settlement and accessibility. There are several other Local Service Centres constrained by environmental designations such as the Cotswolds AONB, Special Landscape Areas and Conservation Areas. Tiddington is not one of these and reflecting its proximity and sustainable connections to Stratford-upon- Avon we consider it is one of the most suitable and sustainable locations in the District for growth. 9.12 As set out above, the Site is located entirely within Flood Zone 1. From a heritage perspective, the Site does not lie within any Conservation Area, nor does it host or lie within the vicinity of any Listed Buildings. The nearest is the Grade II Listed ‘1, New Street’ on Main Street, approximately 0.4 miles to the north-west. Given the separation by existing built form and distance, it is considered that none of the Listed Buildings or their settings in Tiddington will be impacted by any future development on the Site. 9.13 There are opportunities to link up the PRoW route dissecting the Site with the proposed development and to enhance pedestrian and cycle access through the Site. 9.14 The accompanying Vision Document is supported by technical information to demonstrate how the Site could deliver a policy compliant provision of affordable housing. This will help to make a significant contribution to the affordable housing needs of Stratford-on-Avon Borough Council. Planning Policy Designations 9.15 We will reserve commenting on emerging policies specific to the Site and any key policy designations during the next Local Plan consultation when a draft Plan and draft Policies are published. Stratford-upon-Avon Neighbourhood Development Plan 9.16 The Stratford-upon-Avon Neighbourhood Development Plan was ‘made’ on the 17th December 2018. Policy H2 seeks to prevent further coalescence between Tiddington and Alveston by proposing a ‘Strategic Gap’ to preserve the setting and individual character of the settlements. A small area of the eastern boundary of the Site is within the Strategic Gap designation. In line with Policy H2, the following uses are considered acceptable within the Strategic Gap; The reuse of rural buildings; agricultural and forestry-related development; playing fields; other open land uses; and minor extensions to existing dwellings. The Vision Document has accounted for the Strategic Gap and no built form besides part of the access will fall within it. The landscape -led Concept Plan seeks to create a soft edge to the settlement to protect its character and that of neighbouring Alveston. Site Selection Process 9.17 As set out above, we previously submitted representations to the SAP, mostly recently in July 2022 to the Revised Regulation 18 Preferred Options Consultation. Whilst we acknowledge that Sites submitted in the ongoing second Call for Sites should not duplicate previous submissions, we wish to reiterate comments made previously as our client disagreed with the conclusions of previous SHLAA assessments, most recently the update published in September 2021. We set our comments out below: • Agricultural land – this is ‘red’, although further work is required to establish whether this is best and most versatile agricultural land (BMVAL). Notwithstanding this, for application ref. 15/02057/OUT it was concluded that the benefits outweighed the identified harm where there was a loss of BMVAL. • Relationship to highway network – our Client’s site is ‘amber’. The proforma within the SAP states that any development should provide an access off Main Street. As we note elsewhere, suitable vehicular and pedestrian access can be provided from Main Street and as such a ‘green’ is justified. • Public right of way – our Client’s site is identified as ‘amber’. This should be ‘green’ given the ease in which the PRoW can be protected as part of a development – the Vision Document illustrates this. • Settlement character – our Client’s site is identified as ‘red’, which appears to be the principal reason for discounting it, as the site assessment concludes that ‘development would create a major incursion into open countryside that makes a valuable contribution to setting of the village which mitigation could not resolve effectively’. This is incorrect. As demonstrated in the Vision Document, the development of land between the existing edge of Tiddington and the Strategic Gap supports the visual and physical ‘rounding off’ of the village. It enables a positive and definitive settlement edge to be formed which protects the Strategic Gap, while also preserving the setting and individual characters of the two settlements. The committed and built development surrounding the site should also be considered (as set out below). This justifies the site scoring ‘green’. - L&Q Estates have planning consent for a residential scheme which borders the northwestern boundary of the site. This has development has now been built out. - The Hayfield Homes development has recently been constructed, providing 30 dwellings to the north of the site. Specialist housing also exists north of Main Street. • Non-designated Heritage Asset – It is not clear why our Client’s site is ‘red’. The Vision Document sets out that while there are a few listed buildings in the vicinity of the site, it is considered that there will be no unacceptable impact on the significance of these assets. There is recorded archaeology on the site, as identified in the Historic Environment Record, in the form of cropmarks. Whilst not clear, it appears that these records have led to the ‘red’ in the Council’s assessment. The presence of non-designated archaeology in and of itself does not result in the sterilisation of the site. As per normal application procedure, investigation and mitigation can ensure any archaeological remains are suitably incorporated into a sensitive design. The Heritage and Archaeology Briefing Note (see Appendix 2) sets out that any potential archaeological remains will not represent an overriding constraint to the deliverability of residential development within the Site. • Landscape sensitivity – our Client’s site is ‘amber’, despite it falling outside of the Special Landscape Area. In our view, the site is not particularly sensitive in landscape terms and further evidence can be provided to demonstrate this. On the basis of the work we have carried out so far as part of the Vision Document, the site should be scored ‘green’. • Pollution – it is not clear why our Client’s site is ‘amber’ when a number of others nearby, including the draft allocation, are ‘green’. • Suitability (technical) – the SHLAA notes that our site as ‘amber’, due to ‘provision of vehicle access’ and ‘proximity to sports ground’. Regarding the latter, with proper masterplanning this will not be a constraint in terms of amenity for future residents or the operation of the sports facility. Financial contributions / CIL receipts from the development of our Client’s site could in fact support the expansion or improvement of the sports facilities if required. In terms of the former, as noted on the Vison Document, a suitable access is achievable and further evidence will be provided to demonstrate this. A ‘green’ score is warranted. • Deliverability – our site is considered ‘red’. The site is available for development now and is promoted by an established residential land promoter with a demonstrable track record of early delivery. Works to implement the new allotments are scheduled to commence imminently. This site can contribute to housing supply in the first five years of the Plan and as such should be ‘green’. • Viability – our site is viable and can deliver a policy-compliant housing development. As such it should be ‘green’. In line with the SHLAA Site Evaluation Criteria, we consider that the site should be reassessed overall as ‘green’, reflecting that it is free from significant constraints and is available now for early delivery of housing. Concept Masterplan 9.18 An initial Concept Masterplan has been provided as part of this representation, to demonstrate the development potential of the Site and offer one potential design approach which supports balanced growth and serves to reinforce Tiddington as a sustainable village settlement (see page 23 of the accompanying Vision Document). It has sought to build on the opportunities identified in the Vision Document. On this basis, the Concept Masterplan includes the following: • Proposed delivery of approximately 200 dwellings. The initial Concept Masterplan has sought to create a landscape edge/ buffer to Tiddington, including the inclusion of new woodland. • Allotment reprovisions to create an appropriate access into the Site. The Concept Masterplan shows the location of the new allotments, which fall outside the red -line boundary, for which work is set to commence in March 2023. These plots will continue to be accessed from the existing allotment gardens access on Main Road. • No built form (besides part of the access) within the Strategic Gap to the east of the Site. • The proposed development seeks to retain existing trees and hedgerows. • An integrated sustainable drainage strategy utilises existing landscape features to create a blue/ green corridor and SuDS features to the north-west of the Site. • Vehicular access from Main Street to the north, with clearly defined routes going southwards through the Site. • Retention and enhancement of the PRoW, with an emphasis on linking the Sit to the local movement network. • Multiple Key Public Realm Spaces dispersed throughout the Site to support the function of new and existing communities. • Integration with adjoining developments, including the recently constructed Hayfield Homes and Birnam Mews developments and draft allocation South of Sid Courtney Road. Highways and Access Access Strategy 9.19 Following the agreement with ATAGA and the implementation of the new allotments in the near future, there are no constraints to accessing the Site. The proposed access off Main Street is suitable for the development proposed, with a 30mph speed restriction currently in place. 9.20 As set out in the Vision Document on page 15, a new right hand turn junction is proposed from Main Street onto the Site. This will achieve satisfactory visibility splays without relying on third party land. 9.21 If required, an emergency access to Pimlico Lane can be provided. This is a rural land connecting Alveston through to Banbury Road to the south. 9.22 Further technical input and information related to the access and highways in due course. Cycling and Walking Strategy 9.23 We enclose an Accessibility Review (August 2022) (see Appendix 3) to accompany this representation. This reviews key pedestrian and cycle routes to and from the proposed development. The Report identifies potential small -scale improvements that will benefit pedestrian movements to and from the proposed Site: • An opportunity to improve pedestrian links into the Site via the creation of a new footpath on the southern side of Main Street opposite the Home Guard Club frontage. • A dropped kerbed crossing point opposite the Home Guard bell mouth would also assist with pedestrian movements. Flooding and Drainage 9.24 The proposed development falls entirely within Flood Zone 1. As illustrated on the Concept Masterplan, sustainable drainage features in the form of ponds will be situated at the lowest points of the Site, to the northeast, utilising open spaces. Any existing water courses/ bodies will be retained and integrated into the proposed development. 9.25 The drainage outfall and flooding/ drainage strategy generally will be explored in further detail as the proposed development evolves and progresses. This will be shared with the Council when finalised. SUMMARY 10.1 This representation has been prepared by Barton Willmore, now Stantec, on behalf of Catesby Estates, in response to the South Warwickshire Local Plan Part 1 – Issues and Options Consultation. 10.2 Following the Site’s initial promotion on the Scoping and first Call for Sites Consultation (May -June 2021), we are continuing to promote the site for allocation in the new Local Plan Part 1. We have set out a series of comments on relevant matters set out above. 10.3 The Site is in a sustainable location, directly adjoining Tiddington and approximately 2km to the east of Stratford-upon-Avon. It is connected by public transport and a wide range of amenities and services in the local area. 10.4 Our Site is in single ownership and can come forward immediately for approximately 200 dwellings in a manner that is sensitive to its local context and character, as demonstrated on the appended Vision Document (see Appendix 3).

Summary for Long Compton Parish Council Consideration Part 1 of the new plan is concerned with Strategic Objectives, Growth Strategy and Strategic Policies. Part 2 will deal with detailed policies and will contain the NDPs which will be expected to comply with Part 1. Importantly, the “vision for places” component has been removed from Part 1 and will now be addressed in Part 2 and the NDPs. This is to be welcomed. Based on there assessment criteria, there is no clear winner but there is a clear loser – Dispersed which is marked worse for most things than the others. It has to be possible that this will now be dropped from further analysis and we should encourage this. Even if “Dispersed” is dropped, we would still be expected to accept infills within the boundaries and “windfalls”. Also worth noting that they are still working through the responses to the call for sites (in which our usual suspects put themselves forward) and have gone out with a second call – so who knows what might come of that). The main bit is however about the “Core Economic Opportunity Area” – the corridor from Stratford to Kenilworth via Warwick – which underlines the expectation that most development will be in the north. They deal with the expectation of need for new homes. The WDC/SDC combined area has gone up from requiring 1080 new homes per annum (based on ONS work in 2014) to 1679 (based on 2021 census trends). This is a huge increase and will clearly mean that some difficult decisions will need to be made – most difficult I think will be that quite a lot of green belt land will need to be made available for development (this is all in the north and precisely where the rail/bus/economic model suggests we need new houses). They have however put a lot more thought than SDC ever did into affordability and size. For example, they estimate that of our 1679 new builds, 1386 of them need to be affordable. Quite how they’ll manage this is beyond me! Custombuild remains on the agenda. As does Gypsy/traveller sites – both WDC and SDC failed to meet their plans for progress on these and they will need to do something. We are invited to say whether we want to retain the SDC criteria for selecting sites – we do. There’s some good stuff on climate resilience and zero carbon but nothing controversial. This does however include flooding and water management issues (where there is a recognition of surface water flooding risk). There is however nothing here or elsewhere on waste water management issues which we should I think point out. There is a good general intention to protect and enhance the land and buildings of S Warks. Importantly they have decided not to go for a “design code” at the strategic level but to leave it to Part 2 and the NDPs. This is a good thing and we should welcome it. The section on a “healthy, safe and inclusive S Warks” is good motherhood and apple pie stuff but we might want to ensure that this doesn’t evolve into street lighting and overturning dark skies policies. We might also point out that, in rural areas, a big factor is speeding and that the plan might address this. They talk about a well connected S Warks at length before conceding that rural areas aren’t well connected at all either by public transport or by wifi. I think we need to say that, at the strategic level, and given the plan is supposed to run till 2050, this needs to be addressed with some reasonable targets relating to bus services and connectivity. The last section is about a biodiverse and environmentally resilient S Warks. Here there is a biggish chunk on the Cotswold AONB with commitments to protect and comply with the AONB Management Plan (and the NPPF). There is also a tiny bit on dark skies. We should, obviously support this. Generally, this section is strong and will be important to us as we try to protect our important habitats. The one thing really notable for its absence is “enforcement”. We are going to have a lot of new and quite challenging policies flowing from this work and a load of planners will be doing their best to make sure they are implemented. But there is literally no point in any of them if we don’t have much stronger enforcement arms in the Districts. We should I think say this. Lastly, the list of strategic objectives gives us a good checklist to compare with our existing NDP. If we are not addressing one or more of these (or at least explaining why not) we will be risking providing very clear evidence that our Plan is out of date.

Long Itchington Parish Council welcomes the opportunity to comment on the Issues and Options Regulation 18 consultation stage of the emerging South Warwickshire Local Plan (SWLP). The production of a new statutory development plan that includes the Stratford-on-Avon District Council area is a significant undertaking and the Parish Council commends the authors on the comprehensive nature of the plan. The resources available to the Parish Council make it difficult for us to be able to comment effectively on all aspects of the SWLP. We have therefore focused our comments on specific areas within the SWLP, in particular Chapter 4 (Meeting South Warwickshire’s Sustainable Development Needs), Chapter 6 (Delivering homes that meet the needs of all our communities), and Chapter 10 (A well-connected South Warwickshire). Where possible we have attempted to provide a more general response to other issues and questions within the plan. We have tried to directly address some of the questions highlighted within the consultation document. Where direct answers have been provided we have identified the specific question or section being responded to. However, we have also included some general text to highlight specific issues or concerns. Where possible we have identified the section of the plan (and supporting studies) to which our comments are directed. We acknowledge that this stage of the exercise is to set the overall policy framework at a strategic level and that the selection of individual sites will follow in the future. However, our previous experience of development planning leads us to seek reassurance that the process to select individual sites will take full account of all available evidence regarding those sites. We have identified a number of flaws in the supporting studies accompanying the SWLP itself and are concerned that these documents will be heavily relied upon for the justification for the future selection of specific development sites. We request the opportunity to provide comments (in particular our local knowledge) on any proposed development sites prior to their publication in the Preferred Options version of the development plan.

The Green Belt north of leamington is hugely important to myself and the town I am emailing to voice my disappointment with plans to potential new settlement I would like to comment with the following arguments: 1. The Green Belt north of Leamington is important for many reasons: - It is high quality agricultural land which should be safeguarded for the sake of national food security - Its footpaths offer recreational and health benefits for many people in the town of Leamington Spa who can access the area by foot. The number of people using footpaths increased hugely during periods of lockdowns and has continued since - It prevents a sprawling northwards of the town of Leamington Spa and forms a green "northern gateway" to the town. This in turn helps Leamington to maintain its setting and special character. - It helps to maintain the distinct identities of the towns of Kenilworth and Leamington Spa and prevents them from merging into one another. - It assists in urban regeneration, by encouraging the recycling of derelict and other urban land in line with the government's "brownfield firsts" pledge. 2. It is not necessary or appropriate to develop the Green Belt north of Leamington because: - It is not in line with current Government policy - the statistic used in the Consultation in support of green belt development is misleading. This says that 54% of respondents support the exploration of green belt growth opportunities, without mentioning that 45% of respondents were developers, land owners and businesses. - The Green Belt north of Leamington fulfils all 5 of the stated purposes of the Green Belt - The Green Belt north of Leamington is high quality agricultural land which should be safeguarded for the sake of national food security - The planning team explored options which placed development outside of the Green Belt yet it has presented none of these in the consultation document.

In parts that matter to my area, the “issues and options” review in what I learn is a tentative “desktop exercise,” is an enlightened approach to the need for substantial additional housing in the areas covered by Warwick and Stratford District Councils, stressing a commitment to mitigating any impact on communities. It is refreshing to note the railway line running north from Stratford would no longer be seen as a “preferred planning boundary” inhibiting rational development, but a recognition of its potential to form the centre of small scale developments, e.g. the housing hubs envisaged at Danzey and Wood End, and the possible release of land to the west of the railway and its station at Wootton Wawen. A similar bold crossing of the same “artificial iron divide” at Henley with a suitable estate road system would also be beneficial in reducing potential extra traffic pressures on its characterful High Street and preventing any future encroachment of development onto the narrow, vulnerable green belt between Henley and Wootton. As a Wootton Wawen resident [Redacted text] I have long argued locally that the railway station and the services it can provide would be best supported by having housing around it, as is the case at Dorridge, West Midlands, [Redacted text] and many other places. In its present situation Wootton station – like Henley’s - is on the edge, rather than in the centre of the community and it is evident from the history of railways that vibrant towns and villages have grown around, rather than remaining separated from, this form of transport, as well as having good connecting bus routes. The R.C. archdiocese of Birmingham appreciated this when in the early 20th century they chose to locate the Church of Our Lady and St Benedict close to the then new railway in the belief the village would expand around them both. It did not and the church, though well attended by car users, remains as “isolated” as the railway station. More housing near stations up and down the line will encourage the rail franchise holders to increase the frequency of services. Other improvements to the infra-structure then required at such key points - reliably frequent bus routes, car parks, schools, GP surgeries, improved road junctions, traffic calming, mains sewerage etc – will need encouragement, and it has to be accepted, financial, professional and political support from the local authorities, as part of the plan for more housing. Development of some of the identified land to the west of the railway will be a natural way of fully embracing the advantage of trains over cars with regard to congestion and emissions. However, it may be that as first steps towards choosing development sites in Wootton the preference will be to stay east of the railway line in which case the “hidden” parcel of land nominated behind the village allotments and accessed immediately east of the railway embankment and bridge is ideal. This site is close to the station and primary school and within a 5-10 minute walk of pubs, clubs, village hall, shop, post office, churches and main bus stop and within its access from Wawensmere Road able to provide space for much-needed car parking for train users living further afield, saving them a longer drive to employment centres such as Birmingham and Stratford with a cumulative impact on the planet. It is also the location which secured majority support to accept up to 100 mainly average family-size and social properties in a straw poll taken among a gathering of some 80 residents at a special meeting of Wootton Wawen Parish Council on 2nd February to discuss SWLP. It would also be logical, within the 25-year span of the SWLP, for more housing on part of the land behind the 1960s development of The Dale adjacent to the centre of the village. SWLP mentions possible employment opportunities which would give a better economic balance and part of this same area should be considered for business activitity as it is close to amenities including public transport. More immediately there is a case for adjusting the western boundary of the same parcel of land as it extends towards (after review surely not as far as) the sewage works to ensure the line of Alcester Road (B4089) west of the railway is embraced. This would release infill plots for modest-size family homes and form one segment of a circle of development around the station. Because this location is in easy walking distance of railway station, the RC church, school and village centre - well within the 20 minute target of the Local Plan - the goal of also limiting an increase in vehicle emissions would be assisted. Use of some of the various segments of land in this submission would, in the course of time, provide for more than 100 properties – perhaps 200 or 300 - but the idea of 500 homes in Wootton mooted by SWLP would mean approximately a 150 p.c. increase in the present number of homes in the parish (excluding park homes at Wootton Hall), out of proportion to proposals across Warwick and Stratford districts as a whole and no longer could this be categorised by local residents as a “small settlement.” ends

Question S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Answer: Yes – but adequate safeguards must be put in place regarding amount and phasing. We have highlighted in our overall response the issues that must be considered for any further growth in Long Itchington.

I would like to comment on the South Warwickshire Local Plan Consultation with the following arguments: 1. The Green Belt north of Leamington is important for many reasons: - It is high quality agricultural land which should be safeguarded for the sake of national food security - Its footpaths offer recreational and health benefits for many people in the town of Leamington Spa who can access the area by foot. The number of people using footpaths increased hugely during periods of lockdowns and has continued since - It prevents a sprawling northwards of the town of Leamington Spa and forms a green "northern gateway" to the town. This in turn helps Leamington to maintain its setting and special character. - It helps to maintain the distinct identities of the towns of Kenilworth and Leamington Spa and prevents them from merging into one another. - It assists in urban regeneration, by encouraging the recycling of derelict and other urban land in line with the government's "brownfield firsts" pledge. 2. It is not necessary or appropriate to develop the Green Belt north of Leamington because: - It is not in line with current Government policy - the statistic used in the Consultation in support of green belt development is misleading. This says that 54% of respondents support the exploration of green belt growth opportunities, without mentioning that 45% of respondents were developers, land owners and businesses. - The Green Belt north of Leamington fulfils all 5 of the stated purposes of the Green Belt - The Green Belt north of Leamington is high quality agricultural land which should be safeguarded for the sake of national food security - The planning team explored options which placed development outside of the Green Belt yet it has presented none of these in the consultation document.

The protection of rural character and the need to ensure organic growth When taking forward the growth strategy for South Warwickshire we feel it is essential that the SWLP process ensures that the rural nature of many of the villages and communities within the plan area are protected. In 2016 when we commenced the process to develop our Neighbourhood Plan we conducted a detailed survey of all residents. The survey achieved a response rate of over 74% and is therefore highly representative of the views of our community. An overwhelming majority of residents considered that protecting the rural nature of our village was a key priority. This became the key theme underpinning our Neighbourhood Plan. As we have repeatedly made clear, we are not against housing development in our village per se and we recognise that some additional housing will be required during the life time of the SWLP. Our concern is to ensure that the rural nature of our community is protected and that housing growth is organic in nature. We suggest that the site allocation process stage of the SWLP can achieve this in two ways. Firstly, by ensuring that any development sites allocated to our village are limited in size, for example no more than 30 - 40 dwellings as an absolute maximum to be allocated to a single site. Secondly, by ensuring the development of any sites is phased over a longer period. We wish to avoid a repeat of the experience of 2016 – 2021 when over three hundred houses were constructed in just 5 years, one of the sites concerned containing over 150 houses. Over-rapid growth has a significant negative impact on a village community and we request that the SWLP site allocation process ensures that sites are therefore limited in size and brought “on stream” in a phased and controlled way over the lifetime of the plan period. This will help to protect the rural nature of our community and ensure any growth that does occur is more organic in nature. Overall Conclusion Long Itchington Parish Council is broadly supportive of the SWLP and believe the policies are well considered and appropriate. We recognise that this stage of the consultation process is to look at high level strategy and that the development of the plan should be policy driven rather than site-led. We also recognise that significant further growth is required during the plan period and that, despite the recent significant level of house-building, Long Itchington cannot be complete insulated from any additional housing during the 25 year lifetime of the plan (to 2050). We therefore accept that this stage of the process should not involve any detailed discussion regarding the selection of sites as this will follow at the next stage of the process. We also acknowledge that planning authorities need to develop and apply a consistent framework when selecting sites for development. However, we remain concerned about an over-reliance upon high level desk-top studies to justify the selection (and retention) of sites within the plan without adequate weight being attached to other available evidence. Our most recent experience of the site selection process was unfortunately not a very positive one. We discovered that once a site had been included within the plan (the SAP) the District Council consistently ignored both our arguments and the evidence that clearly demonstrated the unsuitability of the site for development. We do not wish to dwell on this situation but we consider this adds validity to our request to be fully engaged in the process at the stage sites are selected for development. Finally, as stated, we accept that Long Itchington may need to accept further housing development during the lifetime of the South Warwickshire Local Plan. All we wish to influence is the overall number of houses that should be built, their type – and the location of where they should be built.

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.

This being a lengthy and weighty document, Bidford on Avon Parish Council’s reply will be more or less limited to how it believes it will impact its village and local community. With this in mind, it has opted to email you its comments as opposed to replying using the form and trusts this will be in order. ·Its preference is for large settlements as this can be developed to incorporate ·Appropriate housing ·Health centres ·Education ·POS/Leisure ·Good connectivity vie rail, bus routes and road ·It is noted the Bidford on Avon is included in a list of settlements with good connectivity. The Parish Council disputes this. It has a bus service, which is not brilliant, and nothing else. The village has become a commuter village with anyone working, mostly outside the village, having to drive – sometimes quite log distances. Further development will only exacerbate an already unsustainable transport system Therefore, whilst it cannot speak for other settlements, Bidford on Avon is not suitable as a dispersal site. ·It is also noted that for the Long Marston Airfield/Meon Vale development to be successful and not cause adverse traffic issues to nearby settlements, such as Bidford on Avon (Barton is part of the village as is Bidford Bridge) the South West Relief Road, or equivalent, must be part of the infrastructure to ensure safe and clean traffic. ·Whilst the Parish Council recognises the need for further development and the government imposed numbers, it is clear that, in order to accommodate these fairly across the South Warwickshire Area, the Green Belt must be reviewed and its restrictions lifted in part. ·On the other hand, the current situation has highlighted the importance of being self sufficient and we are blessed in South Warwickshire with good agricultural land which must be protected against any development that will sterilise the land. This policy would also conform with the current Climate Change and Net Zero visions. ·Better cycling and pedestrian connections – although difficult as roads are already in place and neither have been taken into consideration in the past, special lanes/roads should be identified, especially in rural areas, to connect settlements: this will greatly reduce the necessity of using a car. ·Affordable Housing – Option H2.2a – a single policy for both districts ·Gypsy and Traveller Sites – preference is smaller sites and larger ones can create issues ·Economic needs – policies should be drawn to encourage business whilst ensuring they contribute to a low carbon economy; diversifying the economy and support and sustain rural economies. Policies should encourage local employment to make it sustainable and lower the carbon footprint Policies should encourage investment in the area ·Climate Resilient and Net Zero Carbon South Warwickshire ·Solar and wind power – Option C1. 1b ·Carbon sequestration – Option C3.3 – if it is not Net Zero should not be granted planning permission ·New Buildings ·C4.1b ·C4.2a ·Existing buildings ·C5.a ·Whole Life-Cycle carbon emission assessments ·C6.a ·Adapting to higher temperatures What about cold snaps. If dwellings are built to cope exclusively with higher temperatures, there will be an issue when there is a cold snap. Dwellings should be built to cope with both higher and low temperatures i.e. be well isolated ·Adapting to flood and drought Flooding concerns are an issue in Bidford on Avon Parish with 2 rivers (Avon and Arrow) and the Smallbrook. This concern has grown with the number of developments taken place close to Smallbrook and the River Avon. (The development by the rover Aoorw resulted in it being flooded twice and a Flood Alleviation Scheme having to be built) In view of this Option is C8a ·Mitigating Biodiversity loss Amenity space must be a priority both for new development and existing. For example, an extension to include a conservatory, or similar, should not be permitted if it takes up more than 25/30% of the garden (amenity) and this should be a consideration when allowing new development. ·Flooding and Water Management Option C1 1b ·Flood Risk As mentioned above, flooding is a great concern locally and both Council and local residents do not feel enough attention is given to this when considering planning applications. The LPA appears to be too much in awe of the EA, whose replies are often irrelevant and appear to be more of a “copy and paste” exercise, than taking note of local knowledge and concern. ·A Well designed and beautiful South Warwickshire Can one say “if only”. Most housing developers [do not seem to] take the local scene into account: they simply modify their template to fulfil the minimum requirement to get planning through. Design should be individual to a locality and the LPA should work with local councils when the latter work on either their new NDPs or review their existing ones and they should be encouraged to pay more attention to the design of their housing to ensure the landscape and streetscene remain harmonious and in keeping with the surroundings. ·Healthy, Safe and inclusive Warks Many of these issues have already been tackled above. ·Pollution ·To minimise pollution – better cycle and pedestrian connectivity to reduce use of car ·Local employment – reduce use of car ·Electric vehicles – it would appear to be the solution t least in the short term – need to ensure there are sufficient charging points that are both efficient, quick and offer value fir money ·HiA and ensuring the built environment provides healthy and inclusive communities ·New developments should only be permitted if they deliver good infrastructures, cyle/pedestrian routes, POS/Leisure facilities and the housing good amenity space and facing the right way ·POS ·As above. Policies should force developers to deliver these, as well as good sized gardens ·Well connected SW This is a laudable vision but has its difficulties as public transport is private, so the Principal Authorities can persuade but not demand. Better parking at railways could help and this could be part of the required infrastructure. ·Good bus service – not sure how this can be delivered as companies are private ·Roads – minimise private traffic so that freight can move easily and swiftly. Ensure any new roads are built with the capacity to take on more traffic in the future ·Rail – again private but good parking facilities could be part of planning ·A biodiverse and environmentally resilient SW ·As already mentioned, the Green Belt should be reviewed ·Landscape is important as is agricultural land and should be protected. AONB and Special Landscpae areas should continue to be protected as once lost, they are lost ofrever

Q-S3.2: Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Dependent on the results of the urban capacity study, it could be that brownfield development forms a part of our development strategy. Brownfield sites are frequently found within towns and can therefore often accommodate a higher development density. Prioritising development on brownfield land, especially at higher densities, might reduce the need for greenfield development. However, instead of developing all brownfield sites, this option looks to prioritise brownfield redevelopment in line with the identified growth strategy, where it can be proven the site is in a sustainable location, or when the development can show that it would have a positive impact on the sustainability of the area. In some instances brownfield redevelopment can exacerbate issues and result in development occurring in unsustainable locations. This option aims to reduce such development. Option S3.2b: Prioritise development on brownfield land, incorporating existing buildings into development proposals wherever possible, irrespective of its location This option looks to prioritise the redevelopment of all brownfield land irrespective of whether the site is in a sustainable location. Whilst redevelopment of brownfield land is, on the whole, a sustainable approach, locating redevelopment in unsustainable locations can sometimes exacerbate issues within an area, and this is a risk of prioritising all brownfield sites for redevelopment. Option S3.2c: None of these 2.4 It is noted that the South Warwickshire Urban Capacity Study (October 2022) has concluded on capacity that: ‘This capacity of around 19,950 compares to a housing need for South Warwickshire over the new plan period of 30,750. This housing need figure is subject to change, and is also likely to require the addition of a buffer to allow choice and competition in the market in accordance with Planning Practice Guidance. We have sought to ensure that the assumptions underlying these figures strike an appropriate balance between conservatism and optimism to ensure robustness – whilst there may be some scope to further optimise capacities, particularly if the SWLP were to include policies to require the higher end of our established optimised density ranges, this is likely to require a higher burden of evidence in order to ultimately demonstrate that the SWLP is a sound local plan. A theoretical exercise to consider the potential yields from car park consolidation has indicated that between 800 and 3,400 dwellings could be created. This would however require significant levels of intervention and management to be realised. The shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire, where we have identified potential yields of up to 3,400 dwellings. However, this would necessitate a significant programme of intervention and management in order to be realised. It may also be possible to apply the optimised densities established through the Urban Capacity Study to some sites which have been allocated in existing local plans but which do not yet have planning permission (Site Category 2). However, whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.’ 2.5 Therefore, the Council(s) evidence base clearly demonstrates the need for the release of greenfield. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes | No | Don’t Know 2.6 Yes, we consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. 2.7 South Warwickshire has a dispersed settlement pattern (as set out in Policy CS.15 of the adopted Stratford-upon-Avon Core Strategy) and is home to a significant number of existing settlements of varying sizes. The explanatory text under Issue S4 sets out that there are nine towns (Alcester, Henley-in-Arden, Kenilworth, Royal Leamington Spa, Shipston-on-Stour, Southam, Stratford-upon-Avon, Warwick and Whitnash), at least 82 villages and hundreds of hamlets. 2.8 Issue S4 sets out that the South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet development needs to 2050. However, in deciding upon the best distribution strategy for new development within South Warwickshire, it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements (of all categories). 2.9 Wilmcote is categorised as a ‘Category 2 Local Service Village’ in Policy CS.15 of the adopted Stratford-upon-Avon Core Strategy. 2.10 Wilmcote offers a large range of services and facilities, including a pub; social club; church, primary school; play area. There are several bus stops in the village and there is a train station to the east of the village. The village is relatively close to Stratford-upon-Avon. 2.11 The site is located immediately adjoins the built-up area boundary of the village. The promotion site would be well connected to the built-up area of and would constitute sustainable development. 2.12 Given the pressing need for additional housing within the Stratford-upon-Avon District, Wilmcote is clearly a sustainable location to accommodate additional housing growth. The site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the site should be allocated as a residential site within the South Warwickshire Local Plan. Q-S5.2: Do you think new settlements should be part of the overall strategy? 2.14 The Bird Group does not object to the consideration of new settlements as part of the Council’s Growth Option. 2.15 A range of sites varying in scale and size should be explored in order to secure the delivery of new homes. The expansion of existing settlements and new settlements allocated in the Local Plan should also be explored further to see whether there is capacity to be extend these further. Smaller sites are likely to have no significant infrastructure or utility constraints. The site can be accessed off public highways, the site is in the control of a developer (the Bird Group) which makes it a deliverable site Q-S9: Please select the option which is most appropriate for South Warwickshire 2.23 A higher limit is appropriate for individual sites this will ensure flexibility and a subsequent increase in housing delivery. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire 2.24 All settlement boundaries should be reviewed as part of the SWLP, this will ensure consistencies of approach between Stratford-upon-Avon and Warwick Districts, out of date boundaries can be reviewed which and there could be a subsequent increase in housing delivery.

To whom it may concern: I enclose some comments relating to the issues and options consultation for South Warwickshire in relation to Bearley. 1. If Bearley is to be considered a small settlement for development close to a railway station, current rail links would need to be considerably improved. There is no direct route to the north and frequency of trains to Leamington and on to London are very infrequent. 2.Transport links: I would propose that cycle paths could be extended from Wootton Wawen to Bearley allowing for a safe cycle to and from facilities in Henley in Arden and the railway station in Henley Arden. Additional frequency of bus links to Stratford and Henley-in Arden would also be required to accommodate any increase to the population of Bearely. 3. The area of community woodland owned by Heart of England forest needs to be included on the map and excluded from any housing development.

I support the concept of a 20 minute neighbourhood however I believe it would be difficult to achieve this by adding huge numbers of houses on the edges of Stratford-upon-Avon and other towns within south Warwickshire. This concept can however be achieve on a new settlement. By adding large amounts of housing to the edges of towns creates isolation and community cohesion. On a new settlement, providing that the infrastructure is in place beforehand, a new community is created immediately. In south east Stratford there are two choices – to have 3000 houses tacked onto an already existing settlement or creating a new settlement with its own infrastructure. My choice would be a new settlement. We need to look closely at adding 3000 houses to the edge of Stratford – the viability of social inclusion, the viability of physical infrastructure – roads, rail, schools, community centres, pubs and shops. There would be none of this by adding this number of housing to south east of Stratford. A new settlement with infrastructure in place is, in my opinion, the only alternative.

Q-S1 – Please select the strategic green and blue infrastructure option which is most appropriate for South Warwickshire We fully support the Local Plan including policies on the provision of strategic blue and green infrastructure. However, the preparation of the Plan should not be delayed by the production of the Local Nature Recovery Strategy. In addition, the Local Nature Recovery Strategy will not be tested in the same way development plan policies will through the examination process. It is, therefore, our view that the preferred approach should be Policy S1a, identification of strategic green and blue corridors in the SWLP in advance of the preparation of a Local Nature Recovery Strategy, so that this policy can be brought forward in a timely manner and tested through the examination process. It is noted that page 34 of the Plan advises that it is anticipated that the Part 1 Plan will set out the development principles and associated blue and green infrastructure required for the broad locations that are identified, and the Part 2 Plan will provide more details on the strategic locations and also set out the development principles and details on the non-strategic locations identified for growth. As detailed elsewhere within our representations, we object to the preparation of a two part plan. However, if this is ultimately the preferred approach the Part 1 Plan should not defer to the Part 2 Plan for additional details on the strategic locations for growth as it may delay their delivery. The policy guidance for the strategic allocations contained within the Part 1 Plan should be sufficient for them to be brought forward immediately, without having to delay the preparation of applications until the completion of the Part 2 Plan. The Part 1 Plan will need to make it clear that the strategic sites can be brought forward for development upon adoption of the Part 1 Plan in order to ensure that there is a continue supply of housing and employment land. QS2 – Please select the intensification options which are most appropriate of the South Warwickshire Whilst we fully support making the best use of available sites, the plan needs to be realistic in terms of the ability of an intensification policy to deliver additional development. Page 39 of the Draft Plan advises that intensification can be achieved in a number of ways. We comment on these options as set out below: • Conversion of upper floors of buildings to residential use We have no objection to this proposal, however, permitted development rights and positive planning policies in general have facilitated in bringing the upper floors of buildings back into residential use for a number of years. The inclusion of a policy supporting such proposals is unlikely to result in any significant increase in dwellings. • Additional storeys and buildings This is an unreliable source of housing. There needs to be an understanding of whether buildings are structurally capable and designed in such a way to allow additional floors added to them. Also, there may be design implications and visual impact issues associated with the creation of additional stories. There have been permitted development rights in place for a number of years that allow for the development of two extra stories of accommodation on certain buildings, meaning that such schemes can already come forward in a number of instances. This is unlikely to be a significant source of supply. • Re-use of empty homes When a home is empty it is often for good reason. For example, an elderly person going into care accommodation with the hope that they may return home, or general churn in the housing stock. Furthermore, re-using an empty home is not a “net” source of supply unless once the property became vacant it was recorded in the housing land supply calculations as a loss of a dwelling, which we very much doubt it will have been. There is the potential for there to be double counting from this source of supply. • Infill in residential areas There are positive policies in place for filling the gaps in street frontage and developing disused garage blocks within the adopted Local Plans. A policy supporting infill development is unlikely to result in additional sites coming forward beyond those that are already available. We have significant concerns with the suggestion that car parks could be developed for housing. A car parking strategy would need to be prepared in order to establish whether these car parks are required, as removing car parks could impact on local shops and services where customers use the car parks, or reducing car parking space available in residential areas resulting in additional on street parking. In addition, all of these sources of supply would, in effect, be windfall sites. They are not a new source of supply that will be boosted by the inclusion of a policy in the SWLP. In terms of new developments there needs to be a realistic consideration of the net developable areas and densities that can be achieved. In order to secure high quality design, new developments will need to provide on site open space, green infrastructure and have the ability to satisfy biodiversity net gain requirements This is likely to impact upon the net to growth land ratio available. Indeed, if it is assumed that 40% of greenfield sites will be required for green infrastructure and biodiversity net gain offsetting, this is likely to reduce the total net developable area to around 50% of the gross when infrastructure requirements are considered. Indeed, we note that the plan’s ecological policies suggest that 50% of sites may need to be set aside for green and blue infrastructure (Option C9.1a). Furthermore, we expect the Plan will require a variety of house types to come forward, ranging from bungalows and apartments, to larger 3, 4 + bed properties. Sufficient car parking must be provided within residential schemes in order to try to avoid on street car parking. There will also be areas within the Plan, such as on the edge of settlements and villages, where densities will have to reflect the character of the surrounding area in order to provide a high quality design. In summary, whilst we have no objection to the inclusion of an intensification policy, it is our view that it is highly unlikely to result in significant additional development and should not be treated as a new source of housing land supply beyond that expected from windfalls. Q-S4.1 – Do you think the growth of some of our existing settlements should be part of the overall strategy? Yes. The growth of the existing settlements should be a key part of the growth strategy of the Plan. The SWLP’s housing and employment requirement should be delivered principally through the expansion of existing towns and settlements. The level of development directed to each of the settlements within the plan area should be influenced by a series of factors. This includes the level of service provision within each of the subject towns and the nature of the development opportunities being proposed in these locations. Southam should be a priority area for housing allocations. It is not constrained by the Green Belt. The town has in excess of 6,500 residents and approximately 2,800 dwellings. The town centre provides a range of shops, services and facilities including a number of schools, a leisure centre and library, medical centres, a police station and a post office. There are good public transport services to Leamington Spa, Coventry, Rugby and nearby villages. There is a well established employment area on Kineton Road that provides a range of jobs. The town has been successful in attracting a number of large companies. The town functions as a service centre for much of the eastern part of the district. A large number of rural communities look to the town for their everyday needs. Southam College strengthens the town’s role as the local secondary school. It is one of the largest settlements in Stratford District and is clearly a sustainable location for additional development. Q-S5.2 – Do you think the new settlements should be part of the overall strategy? The development of new settlements can be an effective way of delivering a significant amount of housing and supporting infrastructure through the plan making process. However, new settlements that require a complete infrastructure package will, in all likelihood, take at least 5 to 6 years from the allocation plan to start to deliver housing. They must, therefore, be supplemented by smaller and medium sized allocations. Vistry’s land interest at Southam can provide 750 0- 800 dwellings in the short term significantly boosting the supply of housing whilst any new settlements allocations are realised.

Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes. Sustainable settlements should accommodate growth not only to bring about a balanced and deliverable spatial strategy but also to ensure their continued viability and vitality. As the councils will be aware freestanding new settlements take a long time to commence development and are often reliant on funding entirely new infrastructure which can be challenging to realise in practice. In addition, the councils will need to identify sites that are capable of coming forward in the early years of the plan period to establish a five year housing land supply. Sites on the edge of existing settlements are best placed to meet this need provided they can mitigate their own impacts on local infrastructure. Q-S5.2: Do you think new settlements should be part of the overall strategy? No. We understand the rationale for and the benefits of new settlements where there is suitable and deliverable land available for them. For example, there was spatial logic to the Long Marston and Lighthorne Heath new settlements identified through the adopted Stratford District Council Core Strategy as one was partially previously developed land and the other near a strategic employment site. However, the new settlement options identified in the SWLP appear to lack such robust logic. Half are proposed to be located in the Green Belt and whilst we are generally supportive of releasing Green Belt land to meet development needs where there is a strong sustainability case to do so and where harm to the Green Belt can be minimised or mitigated, the creation of freestanding new communities within the Green Belt will have a considerable impact on its openness and the perception of its openness. The Green Belt new settlement options also happen to be the only locations which have existing train stations. The other options are reliant on new stations being built which is a considerable undertaking and there is no evidence to indicate, notwithstanding the size of any given potential new settlement, that these could be operationally accommodated within the existing network. We understand the rationale for focusing growth around railway stations and corridors to make best use of public transport options to address climate change, but we consider the same benefits could be achieved through more proportionate release of land around a greater number of existing settlements with rail and other public transport connections. We do not consider that a railway and public transport-led strategy must be weighted in favour of new settlements and there is a lack of evidence to indicate that this is a sustainable outcome. Issue S6: A review of Green Belt boundaries We support a review of Green Belt boundaries. We agree that avoiding the Green Belt entirely will not generate a sustainable pattern of growth and is impractical to deliver the ambitious scale of development envisaged by the SWLP. Many of South Warwickshire’s more sustainable settlements are located within the Green Belt and we consider that options to deliver new housing in these locations should be fully explored and acted upon. A comprehensive Green Belt review is key to achieving this.

Stoneleigh Park – SWLP Objectives Stoneleigh Park is a well-established and successful business park which has a number of long standing tenants present on it. It is a national hub for businesses with an emphasis on food production, equine and livestock husbandry, sustainability, renewable energy, and the wider rural economy, who all benefit from co-locating in one place. Running alongside the business park and its activities is a successful events business that covers a wide range of interests and specialisms. It attracts a large number of visitors to the site and into the local area, thus contributing to the local economy in terms of overnight stays and spend in the local area. Warwick District Council has supported the ongoing growth and expansion of the Park and its activities through the grant of an earlier outline masterplan planning permission (W12/0766) and the inclusion of a site specific policy in the current adopted Local Plan facilitating its development (MS2 – Major Sites in the Green Belt). The Park, however, remains in the Green Belt which presents its own challenges when looking at future options to achieve the planned growth. Furthermore, the construction and operation of HS2 through a significant proportion of the Park is impacting and will continue to impact on the Park’s attractiveness to rural business and its environment generally. Whilst the arrival of HS2 and its route has been known about for a number of years, the preparation of the SWLP now presents an opportunity to put in place policy guidance to assist in the re-organisation and reconfiguration of the Park to respond to the arrival of HS2 . It also provides the opportunity to put in place a positive policy to facilitate the evolution of the Park including identifying a range of appropriate uses. It is imperative that the SWLP should allow for a greater range of uses than previously supported to enable the Park to respond to the impacts of HS2 and the changes to the employment market. We are seeking to have the whole of the existing Park removed from the Green Belt and a new policy put in that clearly sets out the parameters and uses to guide the future growth and expansion of the site. HS2 are currently constructing a compound on land in the control of MPTL to the north of the existing Park, between the B4115 and the A46. Once HS2 is completed, in the early part of the Plan period, the compound area and land will be returned to MPTL. The compound constitutes previously developed land. The compound includes large areas of hard standing, roads and supporting infrastructure that can be repurposed once HS2 no longer require it. The improved A46 Stoneleigh junction alongside the roundabout access being constructed off the Stoneleigh Road create a high quality vehicular access to the site. Significantly, HS2 have also brought utilities into the site including water and power. It is substantially more sustainable to repurpose this site, taking advantage of its previously developed land status and infrastructure provision, rather than for it be ‘greened’ over. Particularly when it is inevitable that the SWLP is going to have to bring greenfield sites forward for development. There is also an implemented planning permission for the development of a 9,525 sqm building for use as a farmers market to the north east of the Stoneleigh Road in this location. MPTL are, therefore, also proposing that this land is released from the Green Belt and allocated for additional employment development to help meet the needs of the District and wider sub-region. Together, the compound land and site of the RFM are referred to as the Kingswood Business Park. The broad extent of this area is identified in orange on the masterplan provided at Appendix 2. The Kingswood Business Park will be a sustainability led development. It provides the opportunity to deliver significant biodiversity net gain, as well as encompassing innovative renewable energy provision. It is envisaged that it will be a hub for advanced manufacturing and life sciences. Furthermore, it provides the opportunity to create sustainable and good quality connections into existing highways infrastructure. This includes the potential for the development of a link road through the site that could continue across land in MPTL control to provide better access to Stoneleigh Park in the vicinity of Gate 3. This would significantly enhance the market appeal of Stoneleigh Park given that the current main site access is removed from the A46. The proposed highways improvements could also create a bypass to Stoneleigh village through the Kingswood Business Park and Stoneleigh Park removing significant amounts of traffic from the village. Finally, MPTL are also promoting an area of land adjacent to Stoneleigh Village for new housing, of approximately 100 – 150 dwellings. This matter has been addressed in the previous Call for Sites submission and consequently is not repeated in this submission. The proposed schemes also have the potential to link into a number of other local and significant developments that are already planned and in some cases already under way. The proposals, therefore, will not only deliver a range of benefits in their own right but will create wider sustainability benefits for the District, the South Warwickshire area and sub-region. Key to achieving this is how the developments will respond to the Climate Change agenda in order to deliver truly sustainable development. The main benefits that the sites can deliver are highlighted below and expanded upon in the respective Call for Sites submissions for the respective sites. They include: • Delivery of new high quality employment floorspace and accommodation that will meet a variety of needs across a range of different sectors, thus contributing to meeting the employment and economic growth objectives of the two authorities but also contributing to the wider sub-region. It is anticipated that the focus will be advanced manufacturing, life sciences, sustainability and research and development. • Delivery of a well-designed and attractive Business Park that will incorporate high levels of green infrastructure and areas for biodiversity net gain in a landscaped and treed environment, thus creating a pleasant environment for users of the Park and helping with their well-being and mental health. • Construction of new buildings that are energy efficient / carbon neutral which will have a direct impact on contributing to addressing climate change and reducing energy use. • Ability to deliver highly accessible business and employment development that is connected to new planned housing SUEs at Kings Hill and East of Kenilworth, thereby creating opportunities to move between them all by modes of transport other than the private car. • The potential for the creation of a link road from the Stoneleigh Road potentially using the roundabout that is being constructed by HS2 to serve The Kings Wood Business Park and create new and improved access to Stoneleigh Park, which will directly benefit the local highway and residents of Stoneleigh Village who will see a reduction in Park related traffic passing through the village as a result. • The opportunity to connect into wider local public transport schemes such as the new train station to serve the university and rapid rail transit system that has been mooted as an option. • Opportunities to create significant biodiversity net gain well beyond minimum standards on land within the control of MPTL, to help with nature conservation, climate change flood alleviation measures and potentially public access. • Facilitating public access to the wider estate, including the river corridor. The indicative Masterplan Provided at Appendix 2 includes large area of Green Infrastructure and semi natural open space that help create public access to the Green Belt and enhances its environmental quality, in accordance with the requirements of paragraph 142 of the NPPF. • Delivery of new housing, including affordable housing to help meet the needs of the Districts.

Q-S1 – Please select the strategic green and blue infrastructure option which is most appropriate for South Warwickshire We support the Local Plan including policies on the provision of strategic blue and green infrastructure. However, the preparation of the Plan should not be delayed by the production of the Local Nature Recovery Strategy. In addition, the Local Nature Recovery Strategy will not be tested in the same way development plan policies will through the examination process. It is, therefore, our view that the preferred approach should be Policy S1a, identification of strategic green and blue corridors in the SWLP in advance of the preparation of a Local Nature Recovery Strategy, so that this policy can be brought forward in a timely manner and tested through the examination process. The SWLP will need to remove land from the Green Belt to meet its employment and housing requirements. Paragraph 142 of the Framework advises that where it has been concluded it is necessary to release land from the Green Belt for development, plans should set out ways in which the impact of removing land from the Green Belt can be off set through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. This requirement can be combined with the SWLP’s green and blue infrastructure policies. Enhancing environmental quality of Green Belt land through the provision of green and blue infrastructure can help meet this requirement on Green Belt sites.

REF: South Warwickshire Local Plan - Issues and Options Consultation: Chapter 4, Issue S6: A Review of Green Belt Boundaries. I write to register my comments on the current South Warwickshire Local Plan, as detailed above. I wish to object to the changes to Green Belt Boundaries around Leamington Spa, where I have resided for over 40 years. I am concerned that the Green Belt is not given sufficient weight in the Issues and Options Consultation on the South Warwickshire Local Plan. In my opinion, the Green Belt around the North of Leamington fulfils all of the five stated purposes of Green Belt land. The Government has recently made it clear in a letter from the Secretary of State for Levelling Up, Housing and Communities, that local planning authorities such as Warwick District Council are not expected to review the Green Belt to deliver housing. Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is, to quote the letter from Michael Gove MP “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The Green Belt around North Leamington is recognised as a genuine constraint to development. One of the most important reasons for a Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land and the Secretary of State’s letter in December also made a “brownfield first” pledge which should be the basis of the way that a District Council such as Warwick responds to unmet housing need in other neighbouring authorities. So, the “brownfield first” pledge should be reflected in any duty to cooperate with other local authorities, ensuring that larger conurbations do look hard at creative brownfield solutions close to where people work. Developers may well prefer to use greenfield sites as these are easier to develop, but that appears to go against the latest Government advice. I am also concerned about the statistics in Chapter 4, issue S6 that state that 54% of respondents to the first consultation, Scoping and Call for Sites, supported “exploration for growth opportunities” in the Green Belt. The planning team appear to be using this as one of the justifications for reviewing Green Belt boundaries. However, I believe some 35% of respondents to that consultation were developers and 10% were businesses or landowners, suggesting that only a small proportion of other respondents were in favour. The heavy weighting towards groups with vested interests should be treated with caution and certainly not used as justification. The letter from the Secretary of State does in itself justify halting the current work on the South Warwickshire Local Plan until the updated NPPF is finalised. This would enable the South Warwickshire Local Plan to be realigned with the Government’s clear intention for planning authorities to have more power to resist identifying Green Belt land for development if the only solution for meeting assessed housing need would be to build on Green Belt land. The Green Belt around the North of Leamington is a highly valued open space. As a local resident I have, over many years and continuing to this day, found these spaces very valuable both in terms of my physical and mental health. I would also comment that whenever I see or use these spaces, it is rare not to find other members of the public using the space for walking, running, dog-walking, bird-watching etc. It is visually of a very high quality and has a number of easily accessible public footpaths across the fields. When walking these footpaths I have enjoyed seeing a wide variety of local wildlife, including deer, badgers, buzzards, red kites and woodpeckers to name but a few. These footpaths were heavily used during lockdown, and the gratitude that residents felt to the local farmer for his understanding was evidenced by the thousands of pounds raised for the charity of his choice, to which I also contributed. The farmland is high-quality agricultural land and makes an important contribution to sustainability and security of food supply. I believe that this is a critical issue for this country going forward and a major reason for preserving green belt agricultural land. It is also to be noted that recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The Government is clear that it seeks to protect such land from non-agricultural development, and indeed the National Planning Policy Framework states, “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality”. The agricultural land provides rural employment and the mixed arable, grazing and wildlife refuge all helps to maintain the wonderful ambience of the rural village of Old Milverton only a short distance from Leamington Spa, but with a totally rural feel. Development within the Green Belt to the north of Leamington Spa would substantially reduce the land that separates the distinctly different towns of Kenilworth and Leamington Spa. This is even more the case since the current Local Plan, which in reviewing the Green Belt removed land to the south of Kenilworth and north of the A46 from the Green Belt. The joint Green Belt study in 2015 highlighted the contribution to preventing the merger of Leamington Spa, Kenilworth and Coventry that this part of the Green Belt makes by stopping urban sprawl, protecting the countryside and preserving the special character of these differing but very special historic towns. The routeing of HS2 in this area has also had a significant negative impact on Green Belt space in this area. The Planning Inspector’s 2017 response to the current Warwick District Local Plan states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p18, para 91). It also points out that: “Development to the land in question would involve a substantial expansion of the built-up area into currently open countryside to the north of Leamington Spa. It would have significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p34, para 201). The construction of HS2 has made the existing Green Belt even more valuable and the Inspector’s wise comments are indeed more relevant now, than they were in 2017. There is concern that the assessments of the two proposed development sites are in the 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both assessments state that the locations would be “unlikely to lead to coalescence of settlements”. However, any development would join Old Milverton and Blackdown to Leamington Spa and bring Leamington Spa close to the southern suburbs of Kenilworth. The Green Belt has a major purpose in stemming the loss of open space between the West Midlands, a major urban conurbation, and neighbouring towns and villages. The proposed developments would significantly reduce that green corridor, and have a detrimental impact. The officers have done considerable work on the Issues and Options consultation of the South Warwickshire Local Plan, but sadly the process is flawed because all five spatial growth options involve some development in the Green Belt. It is even more unfortunate that all of them refer to the Green Belt to the North of Leamington as an area of ‘significant urban extension’. This all appears to ignore the legitimate function served by the Green Belt, and is contrary to very recent Government announcements, the 2015 green belt review and the detailed 2017 response by the Planning Inspector.

REF: South Warwickshire Local Plan - Issues and Options Consultation: Chapter 4, Issue S6: A Review of Green Belt Boundaries. I write to register my comments on the current South Warwickshire Local Plan, as detailed above. I wish to object to the changes to Green Belt Boundaries around Leamington Spa, where I have resided for over 40 years. I am concerned that the Green Belt is not given sufficient weight in the Issues and Options Consultation on the South Warwickshire Local Plan. In my opinion, the Green Belt around the North of Leamington fulfils all of the five stated purposes of Green Belt land. The Government has recently made it clear in a letter from the Secretary of State for Levelling Up, Housing and Communities, that local planning authorities such as Warwick District Council are not expected to review the Green Belt to deliver housing. Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is, to quote the letter from Michael Gove MP “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The Green Belt around North Leamington is recognised as a genuine constraint to development. One of the most important reasons for a Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land and the Secretary of State’s letter in December also made a “brownfield first” pledge which should be the basis of the way that a District Council such as Warwick responds to unmet housing need in other neighbouring authorities. So, the “brownfield first” pledge should be reflected in any duty to cooperate with other local authorities, ensuring that larger conurbations do look hard at creative brownfield solutions close to where people work. Developers may well prefer to use greenfield sites as these are easier to develop, but that appears to go against the latest Government advice. I am also concerned about the statistics in Chapter 4, issue S6 that state that 54% of respondents to the first consultation, Scoping and Call for Sites, supported “exploration for growth opportunities” in the Green Belt. The planning team appear to be using this as one of the justifications for reviewing Green Belt boundaries. However, I believe some 35% of respondents to that consultation were developers and 10% were businesses or landowners, suggesting that only a small proportion of other respondents were in favour. The heavy weighting towards groups with vested interests should be treated with caution and certainly not used as justification. The letter from the Secretary of State does in itself justify halting the current work on the South Warwickshire Local Plan until the updated NPPF is finalised. This would enable the South Warwickshire Local Plan to be realigned with the Government’s clear intention for planning authorities to have more power to resist identifying Green Belt land for development if the only solution for meeting assessed housing need would be to build on Green Belt land. The Green Belt around the North of Leamington is a highly valued open space. As a local resident I have, over many years and continuing to this day, found these spaces very valuable both in terms of my physical and mental health. I would also comment that whenever I see or use these spaces, it is rare not to find other members of the public using the space for walking, running, dog-walking, bird-watching etc. It is visually of a very high quality and has a number of easily accessible public footpaths across the fields. When walking these footpaths I have enjoyed seeing a wide variety of local wildlife, including deer, badgers, buzzards, red kites and woodpeckers to name but a few. These footpaths were heavily used during lockdown, and the gratitude that residents felt to the local farmer for his understanding was evidenced by the thousands of pounds raised for the charity of his choice, to which I also contributed. The farmland is high-quality agricultural land and makes an important contribution to sustainability and security of food supply. I believe that this is a critical issue for this country going forward and a major reason for preserving green belt agricultural land. It is also to be noted that recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The Government is clear that it seeks to protect such land from non-agricultural development, and indeed the National Planning Policy Framework states, “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality”. The agricultural land provides rural employment and the mixed arable, grazing and wildlife refuge all helps to maintain the wonderful ambience of the rural village of Old Milverton only a short distance from Leamington Spa, but with a totally rural feel. Development within the Green Belt to the north of Leamington Spa would substantially reduce the land that separates the distinctly different towns of Kenilworth and Leamington Spa. This is even more the case since the current Local Plan, which in reviewing the Green Belt removed land to the south of Kenilworth and north of the A46 from the Green Belt. The joint Green Belt study in 2015 highlighted the contribution to preventing the merger of Leamington Spa, Kenilworth and Coventry that this part of the Green Belt makes by stopping urban sprawl, protecting the countryside and preserving the special character of these differing but very special historic towns. The routeing of HS2 in this area has also had a significant negative impact on Green Belt space in this area. The Planning Inspector’s 2017 response to the current Warwick District Local Plan states that there is a need “to maintain the separate identity of surrounding villages such as Leek Wootton and Cubbington and avoid significant reductions in the gap to Kenilworth” (p18, para 91). It also points out that: “Development to the land in question would involve a substantial expansion of the built-up area into currently open countryside to the north of Leamington Spa. It would have significant adverse impact on the openness of the Green Belt and the character and appearance of the area” (p34, para 201). The construction of HS2 has made the existing Green Belt even more valuable and the Inspector’s wise comments are indeed more relevant now, than they were in 2017. There is concern that the assessments of the two proposed development sites are in the 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both assessments state that the locations would be “unlikely to lead to coalescence of settlements”. However, any development would join Old Milverton and Blackdown to Leamington Spa and bring Leamington Spa close to the southern suburbs of Kenilworth. The Green Belt has a major purpose in stemming the loss of open space between the West Midlands, a major urban conurbation, and neighbouring towns and villages. The proposed developments would significantly reduce that green corridor, and have a detrimental impact. The officers have done considerable work on the Issues and Options consultation of the South Warwickshire Local Plan, but sadly the process is flawed because all five spatial growth options involve some development in the Green Belt. It is even more unfortunate that all of them refer to the Green Belt to the North of Leamington as an area of ‘significant urban extension’. This all appears to ignore the legitimate function served by the Green Belt, and is contrary to very recent Government announcements, the 2015 green belt review and the detailed 2017 response by the Planning Inspector.

I read with dismay that there are potential plans to build 500 new homes in the sleepy village of Wootton Wawen. However, I do understand the need for housing, especially housing in an area that has a railway network. With this in mind, I am cautiously supportive of the South Warwickshire Local Plan exploring this, providing there are a number of key caveats: 1. Council/Developers to increase Henley in Arden Doctor Surgery Capacity - With 500 homes potentially increasing the population of Henley in Arden by an average of 1000-2000+ new people, the small local doctor's surgery will not have the facilities to accommodate this increase. Before spades are in the ground, money and land needs to be secured for either a new satellite Doctors Surgery in Wootton Wawen or a larger Medical Facility in Henley in Arden. If this isn't done, then the Local Plan will cripple the area medical capacity. 2. Invest in Leisure Facilities - Wootton Wawen largely has a population of an elderly people and there aren't facilities for children or teenagers. With a potential influx of 1000+ children and teens into the village, there needs to be thought on how the Local Plan will entertain this new population and avoid antisocial behaviour. I would recommend that the Council grants permission to Developers who will invest in the area by creating parks, play areas and especially by investing in a renovation of the Wootton Wawen Village Hall to act as a Community Hub for all members of the community and enhance to cohesion of the Village. 3. Traffic Calming and crossing - The main road is already extremely busy with the majority of users exceeding the 30mph speed limit. With an increase of 500-1000 cars into the village, this will add further risks for children and the elderly crossing the road. I would urge the Councils to reduce the speed of traffic in the village by widening the pavements with cycle lanes, planting and better crossing all the way along the village main road I've been a resident of Wootton Wawen for a couple of years now after moving from the Cotswolds. Ive seen Parish Councils try and fight development and fail, rather than trying to embrace change to improve the village facilities for everyone. I'd be happy to be involved in any future consultation.

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.

Q-S2: Please select all options which are appropriate for South Warwickshire: It is essential that Intensification is given top priority and is pursued with urgency. Of the options presented, Option S2a appears most likely to be effective. Q-S3.2: Please select the option which is most appropriate for South Warwickshire: Option S3.2b: Prioritise development on brownfield land, incorporating existing buildings into development proposals wherever possible, irrespective of its location. There are numerous advantages to the re-use of previously developed land so there should be no exceptions. Q-S5.2: Do you think new settlements should be part of the overall strategy? No. Intensification in towns should be the focus with a brownfield-first policy, taking windfalls fully into account. Greenfield developments are not justified. Q-S7.1: Please provide any comments you have on the emissions estimation modelling for the five growth options. All five growth options are invalid because it is not acceptable to turn Green Belt policy off - permanence is the key characteristic of the Green Belt according to the NPPF. Intensification in towns should be the focus with a brownfield-first policy, taking windfalls fully into account. Greenfield developments are not justified. 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? Small scale developments are essential in order to achieve intensification in urban areas and a brownfield-first policy. Windfall sites must be taken fully into account, recognising the increasing trend. The plan period to 2050 is far too long, as recognised in the Options document: "It is difficult to predict where and when these needs will arise, with a plan period running to 2050." Q-S9: Please select the option which is most appropriate for South Warwickshire: Option S9a: Save all existing settlement boundaries. This is particularly important within the Green Belt, in which permanence is its key characteristic. Intensification in towns should be the focus with a brownfield-first policy, taking windfalls fully into account. Greenfield developments are not justified.

Q-S1: Please select the option which is most appropriate for South Warwickshire Option S1b: Do not identify Green and Blue Corridors within the South Warwickshire Local Plan, and instead rely on the production of the Local Nature Recovery Strategy 2.16. While the Respondent does not object to the identification of Green and Blue Corridors in principle (in accordance with Paragraph 20 of the NPPF), they are not convinced that such designations can be robustly evidenced or justified in absence of the Councils’ Local Nature Recovery Strategy (LNRS). The Respondent would therefore err towards not identifying such areas at this stage. Q-S2: Please select all options which are appropriate for South Warwickshire Option 2c. Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes. 2.17. Developers tend to err towards higher densities without the need for a planning policy requiring such. It is the inter-play of policy requirements and the input of stakeholders that tend to drive densities down rather than developer choice. 2.18. The Urban Capacity Study (October 2022), which forms part of the Issues and Options Evidence Base, identifies the biggest constraint to the maximisation of gross developable areas on sites as being the requirement to provide private and shared parking spaces (Urban Capacity Study, Section 3.3, Page 20). Should the Councils therefore wish to optimise densities, careful thought will need to be given to the implication of other policies and requirements on the ability for developers to build at higher densities. 2.19. With regard to Design Codes, while these can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design and density perspective. 2.20. Since developers tend to err towards maximising the efficiency of sites anyway, the preparation of a design code simply to support intensification would seem a disproportionate response to the issue at hand. It would be better if the Councils’ focus on the consideration of the wider implications of policies and standards contained in the plan which are known to drive densities down. Q-S3.1: Please add any comments you wish to make about the Urban Capacity Study. 2.21. The Urban Capacity Study identifies a potential baseline housing supply for the 2025-2050 plan period of 19,950 dwellings. Of this, 6,145 dwellings would be located within existing urban areas and the remainder located elsewhere (including new settlements). 2.22. The conclusion drawn at Section 4.6 of the Urban Capacity Study confirms that greenfield land must be released to meet South Warwickshire’s housing needs and states that: “….whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.” (Section 4.6, Page 37, own bold) 2.23. While the study indicates that the shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire this would seem highly unlikely given the significant programme of intervention and management that would be required for such capacity to be realised. The Respondent would also anticipate the likely yield from such sites to be considerably less than 3,400 dwellings and more likely towards the lower end of the range indicated (800 dwellings). 2.24. In the Respondent’s view, the inevitably of significant greenfield land being required adds considerably to the case for Green Belt release given that it is within the Green Belt that development can be most sustainably located. 2.25. It is agreed that to allow choice and competition in the market in accordance with National Planning Practice Guidance (NPPG) a buffer should be applied to the housing need as suggested in the Urban Capacity Study (Paragraph 4.6). Q-S3.2: Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. 2.26. While the Respondent recognises the importance of re-using Brownfield land, having considered the options presented in the Consultation Document, Option S3.2a is considered most appropriate in South Warwickshire, with Brownfield sites prioritised only where they are sustainably located and in line with the identified growth strategy. To do otherwise could result in unsustainable patterns of development that would conflict with the overarching vision and strategic objectives of the plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Y/N/DK 2.27. Yes. The Respondent agrees that growth of existing settlements should be part of the overall growth strategy for South Warwickshire. As opposed to new settlements, sustainable development at existing settlements has the benefit of being delivered without significant infrastructure investment and within a much shorter time frame. 2.28. Turning to Bishop’s Itchington, the Respondent’s site represents a sustainable and logical extension that is capable of being developed without technical impediment and would assist in supporting existing facilities and the vitality of the rural community in accordance with Paragraph 79 of the NPPF. Such matters are discussed in further detail in the site-specific representation at Section 3.0 of this Statement. Q-S5.2: Do you think new settlements should be part of the overall strategy? Y/N/DK 2.29. Broadly yes. The Respondent is generally supportive of the inclusion of new settlements in the overall growth strategy as they can be an effective way, at least in theory, of delivering new housing where there are barriers to the sustainable delivery of sufficient housing elsewhere. However, in reality, the physical implementation of new settlements is often complex and costly, which can significantly hamper their delivery. The Respondent would therefore caution against over reliance on new settlements in the preferred growth strategy. 2.30. Where new settlements are proposed the infrastructure requirements should be identified and robustly costed to ensure that delivery is viable. The Councils should also take a conservative approach regarding assumed capacity and likely build-out rates and avoid including housing completions from new settlements too early in the plan period. The Lichfield’s Start to Finish (Second Edition) 2020 report may be a helpful starting point in this regard, although any assumptions that are made will need to be fully evidenced having regard to site specific constraints and circumstances. 2.31. To improve choice and competition and help to mitigate the risk and implications of such sites not coming forward within the timescales envisaged it is recommended that a buffer is applied to the housing need, with a greater number of small-medium sites allocated at sustainable settlements to ensure adequate housing delivery in the short-medium term. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? Y/N/DK 2.32. Yes. The Respondent considers it sensible to look to rail corridors as a preferred approach to the identification of potential locations. However, given the problems and delays that can often occur with the provision of new rail services and stations, it considered that the intensification of existing rail services should be considered before new ones. Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 2.33. Given the emphasis on mitigating the impacts of climate change and considering the evidence base prepared to date, the Respondent would agree that Option 2 (Rail and Bus Corridors) would appear to align best with the overall objective of mitigating the impacts of climate change and, on balance, considers this to be the most appropriate option for South Warwickshire. However, in the interests of maintaining the vitality of existing settlements there is also considered to be merit in Option 5 as a hybrid approach. 2.34. It is likely that even with Green Belt release the Councils will need to look beyond the initial list of settlements identified under Option 2 to meet South Warwickshire’s needs in full. On which basis it is recommended that the Councils also look to the next tier of settlements and locations, such as the Category 1 Service Villages identified in the Stratford-on-Avon Core Strategy (which includes Bishop’s Itchington). The benefit of such an approach being a more even distribution of housing across the plan period that strikes a better balance between prioritising development at the most sustainable settlements but also ensures the vitality of sustainable rural communities in accordance with Paragraph 79 of the NPPF. 2.35. For the avoidance of doubt, bearing in mind the accessibility of Bishops Itchington and the magnitude of the housing need to 2050 it is considered that the village could reasonably be included under any of the growth options as a potential location for new housing development (despite only currently being included under Options 5). Such matters are discussed in more detail in the site-specific representation at Section 3.0 of this Statement. 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? Y/N/DK 2.36. No. The sustainability of settlements falling outside of the chosen growth strategy will vary to a significant degree and should not therefore be treated as equal. 2.37. Settlements such as Bishop’s Itchington, which is defined as a Local Service Village under Policy CS15 of the current Stratford-on-Avon Core Strategy, have the potential to accommodate significantly more growth than is being suggested in the current Consultation Document and in the interests of maintaining the vitality and viability of such settlements should not be ignored in the development of a preferred strategy; particularly where they have a good range of facilities and access to public transport services. 2.38. Turning to Bishop’s Itchington specifically it is understood from the Bishop’s Itchington Neighbourhood Development Plan (BINDP) that 117 dwellings have been built in the parish and a further 370 approved in the period since 2011 against an indicative target of 112.5 new dwellings. It would therefore seem irrational, given the inherent sustainability, role and function of the settlement and the clear opportunities for further growth at the village that over the next 25 years development could be restricted to sites of 10 or fewer dwellings under the SWLP. 2.39. In the Respondent’s view, a comprehensive settlement audit should be undertaken for those settlements that fall outside the identified growth strategy to better understand their functionality and relative sustainability. The results of which can then be used to inform an appropriate distribution strategy across these settlements in a less arbitrary and more transparent way. To do otherwise would put at risk the vitality of such settlements in conflict with Paragraph 79 of the NPPF. 2.40. A site-specific representation in favour of the allocation of additional housing development at land off Station Road, Bishop’s Itchington is set out under Section 3.0 of this Statement. Q-S9: Please select the option which is most appropriate for South Warwickshire Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 2.41. Of the options presented the Respondent considers that a consistent approach across Stratford-on-Avon and Warwick District is most appropriate and would therefore lean towards Option S9b as being the most appropriate option for South Warwickshire. 2.42. The Consultation Document notes that one disadvantage of this option is that some non-strategic land allocations will likely not be made until Part 2 comes forward and that it would be difficult to make appropriate revisions to boundaries in advance of these non-strategic allocations being made. The Respondent does not disagree and considers this to be one of a number of disadvantages in proceeding with a two-tier plan rather than a single one as discussed under QP1.2.

Q-S1: Whilst the focusing on green and blue corridors is one way of considering Spatial Growth, there is no reference whatsoever to the need to consider Economic growth and the benefits of economic growth in those corridors. This is particularly helpful in identifying recovery areas and linking that back to economic growth. Economic growth can provide very substantial Green infrastructure particularly in proper and reasonable balanced Masterplanning of development. Comment on the options: Firstly this is a badly worded question because what is required is a new policy that links Environmental protection, environmental enhancement and economic benefits flowing from development that would both assist protection and enhancement. Q-S2: There needs to be a clear policy context between major urban areas and rural settlements where the issues of density are both fundamentally different. Each site has to be judged on its own merits and the benefits that it could bring with economic growth balanced against environmental protection and enhancement. Issue S4: We would support the Table 2 list of settlements and locations which clearly have connectivity and accessibility. This should be separated from density which is a fundamentally different matter to deal with. Issue S5: We would comment that in our opinion it would be better to focus attention on existing settlements, the upgrading of those settlements as this would be sustainably more appropriate than building a new settlement. Infrastructure would be better focused on existing settlements to upgrade existing facilities such as utilities like broadband with the future wants of those settlements in terms of broad provision of community facilities. Q-S5.2: We would suggest that you refer to the paragraph above taking into account the economic and environmental benefits of properly and reasonably expanding existing settlements where there is a rail station linking back to the main rail corridors and where there could be some appropriate sustainable economic employment growth in addition. Issue S10: There needs to be a much more positive approach to settlement growth in order to fulfil the best development strategy for South Warwickshire.

3.0 Land off Station Road, Bishop’s Itchington 3.1. This Section of the Statement seeks to promote land at Bishop’s Itchington, which the Respondent can confirm is under the unified control of Mactaggart and Mickel (Mac Mic Group) and is available for residential development. The Site 3.2. The Respondent’s site at Bishop’s Itchington is situated on the western edge of the village. The village contains a good range of facilities and services, all of which are within walking distance of the site. Such facilities include a Primary School, Convenience Stores, Doctors Surgery, Community Centres, a Takeaway, Pub and Church. 3.3. The Site itself comprises two agricultural fields totaling approximately 18.6 hectares (ha). The fields are enclosed by hedges and divided by a mature hedgerow running broadly north- west to south-east. The landform is generally flat with the highest area, approx. 125m above Ordnance Datum (aOD). Constraints & Opportunities 3.4. The village is relatively unconstrained in so far as it is not subject to any local or national designations (i.e., Green Belt, Special Landscape Area, AONB). 3.5. A comprehensive summary of the site’s constraints and opportunities is set out in the accompanying Vision Document which demonstrates that the site is free from technical impediment and is therefore capable of being delivered for housing early in the SWLP plan period. The Respondent also has adequate control of land to bring forward a comprehensive green infrastructure strategy and provide at least 10% Biodiversity Net Gain. Case for Additional Housing Development at Bishop’s Itchington 3.6. Bishop’s Itchington is defined as a Local Service Village under Policy CS15 of the adopted Stratford-on-Avon Core Strategy. In the context of the current Development Plan for Stratford-on-Avon the village is therefore considered to be a sustainable location for new housing development in principle. 3.7. It is noted that under Policy CS15 Bishop’s Itchington was identified as being a suitable location for approximately 112 dwellings across the plan period 2011-2031 (20 years) although significantly more has been permitted/delivered in the period since 2011 (see response to Q-S8.1). 3.8. Turning to the accessibility of the village, the now made Bishop’s Itchington Neighbourhood Plan (February 2023) states that: “The nearby conurbations of Warwick, Leamington Spa and Coventry are within easy reach for employment opportunities but, since the building of the M40 motorway in the early 1990s and the opening of Warwick Parkway station, there have been further changes to the nature of the village. Easy access to the motorway and rail networks makes the village attractive to commuters working further afield. Aston Martin Lagonda and Jaguar Land Rover operations at the former RAF Gaydon site have further increased the appeal of Bishop’s Itchington as a place to live.” (BINPD, Paragraph 5.5) 3.9. Bearing in mind the accessibility of the village and the magnitude of the housing need to 2050 it is considered that (despite the current Consultation Document identifying Bishop’s Itchington as a potential location for growth under Option 5 only) that the village could reasonably be included under any of the growth options as a potential location for new housing development. However, it is the Respondent’s fundamental position that the development of additional housing land at the village would be commensurate with the guidance in Paragraph 79 of the NPPF in terms of supporting the vitality of rural communities. The Vision for the Site 3.10. It is proposed that land off Station Road is brought forward on a comprehensive basis, although it is equally recognised that not all of the site needs to be developed. 3.11. The Vision Document that accompanies these representations, while it illustrates only one way in which the site could be developed, demonstrates that development off Station Road would be seen as a logical extension of the village. 3.12. Through comprehensive analysis of the contextual, planning and technical parameters it provides evidence that the site is an appropriate location for development, is available now and can deliver new homes within the next plan period without any technical impediment. 3.13. The document also demonstrates that while the site represents development moving further westwards and beyond the proposed BUAB, that through appropriate masterplanning and the use of peripheral boundary planting and landscaping, development could be accommodated in this location without compromising the settlement’s form or character, unlike other sites that are being promoted which seek to extend the village in linear form away from its general nucleated settlement pattern. Conclusion 3.14. It is clear from the accompanying Vision Document that the Respondent’s site at Bishop’s Itchington is not subject to any major constraints. The site’s unified control by a trusted and experienced land promotion company (Mactaggart and Mickel) and its non-dependence upon any major new strategic infrastructure means that the site is readily deliverable. 3.15. For the reasons explained above, it is the Respondent’s belief that the site is the superior option for the accommodation of new homes at the village and accordingly should be allocated for housing development for circa 200 new homes to assist in meeting the housing requirements of the SWLP in a positive and effective way in accordance with both Paragraph 79 of the NPPF and the tests of soundness set out under Paragraph 35 of the NPPF.

Q-S1: Whilst the focusing on green and blue corridors is one way of considering Spatial Growth, there is no reference whatsoever to the need to consider both reasonable expansion of existing settlements such as at Hatton Park as well as reasonable local Economic growth and the benefits of economic growth in those corridors. This is particularly helpful in identifying recovery areas and linking that back to economic growth. Economic growth, in conjunction with farm expansion, can provide very substantial Green infrastructure particularly in proper and reasonable balanced Masterplanning of development particularly for the future of Hatton Park and its extension. Comment on the options: Firstly this is a poorly worded question because what is required is a new policy that links Environmental protection, environmental enhancement and economic benefits flowing from development that would both assist protection and enhancement. Q-S2: There needs to be a clear policy context between major urban areas and rural settlements where the issues of density are both fundamentally different. Each site has to be judged on its own merits and the benefits that it could bring with economic growth balanced against environmental protection and enhancement. Issue S4: We would support the Table 2 list of settlements and locations which clearly have connectivity and accessibility. This should be separated from density which is a fundamentally different matter to deal with. Issue S5: We would comment that in our opinion it would be better to focus attention on existing settlements, the upgrading of those settlements as this would be sustainably more appropriate than building a new settlement. This is particularly the case for a reasonable expansion of Hatton Park. Infrastructure would be better focused on existing settlements to upgrade existing facilities such as utilities like broadband with the future wants of those settlements in terms of broad provision of community facilities. Q-S5.2: We would suggest that you refer to the paragraph above taking into account the economic and environmental benefits of properly and reasonably expanding existing settlements, particularly for places like Hatton Park, where there is a main line rail station at Warwick Parkway close-by and where there could be some appropriate sustainable local economic employment growth in addition linked to the farming activities of this area. Q-S10: There needs to be a much more positive approach to settlement growth in order to fulfil the best development strategy for South Warwickshire.

We write on behalf of CEMEX UK Operations Ltd (CEMEX). CEMEX is a global supplier of construction materials. CEMEX has extensive land holdings within Warwickshire which include s land south of Stockton Road, Long Itchington. The site promoted for residential led development through the South Warwickshire Local Plan. The Long Itchington site is circa 2.08 ha and lies on the edge of Long Itchington (a Category 1 Local Service Village) and comprises an arable agricultural parcel. It is contained by hedgerow and trees to the southern (beyond which is the canal) and eastern boundaries, new residential development to the north and west and an agricultural parcel to the east. A site location plan is attached at Appendix 1. Proposals have been developed for the Long Itchington site, including previous submissions to the SWLP Scoping and Call for Sites consultation in June 2021, the Site Allocations DPD consultation in July 2022 and a pre-application submission in May 2022 and written response dated 6 September 2022. Engagement has also been undertaken with the Parish Council. To support the promotion of the Site through the emerging Development Plan CEMEX has undertaken an exercise to update the evidence base and respond to the amber and red issues identified in the SHLAA (dated 2021). An illustrative layout was also prepared to demonstrate how development can be brought forward on the site (see Appendix 2). The updated evidence base seeks to remove all technical impediments to delivering the site, it is therefore CEMEX’s view that the Long Itchington site is suitable, available and achievable in the short term for housing. The Case Officer’s Pre-application Response (copy enclosed at Appendix 3) suggested that further preapplication advice was required from County Officers in regards to Ecology, Landscape, Heritage, Transport, and Flooding. It should be noted that Stantec held pre -application discussions with Warwickshire County Council as Lead Local Flood Authority which informed the suggested approach.CEMEX has instructed this work and pre-application requests have been submitted seeking further advice. Responses are awaited from Ecology and Landscape. Vectos attended a pre-application meeting with County Highways Officers and the following points and actions were confirmed: • Traffic Generation and distribution - the Highway Authority considers the methodology presented in the Scoping Note, whilst not following the protocol, is acceptable. It is noted that further justification for the proposed methodology should be included within any Transport Assessment. • Traffic Modelling - the Highway Authority raised several points regarding the preliminary traffic modelling included within the Scoping Note. These issues would be resolved in a submitted Transport Assessment. • Site Location - given the proposed site is located immediately adjacent to two residential developments built in the recent past, it is concluded that the proposed site is easily accessible from the highway network and is in a sustainable location. • Access & Layout - The Highway Authority advised on several proposals, which should be incorporated within the proposals including access to the towpath, extension of a footway on Stockton Road and a new crossing facility on Stockton Road. As set out within the Scoping Note, we are keen to encourage sustainable travel and will investigate your proposals further. • Vehicle Access – The Highway Authority noted that their Design Guide indicates a minimum separation of 25 metres between junctions. I can confirm the distance between the proposed and existing junction is circa 69 metres. As such it complies with the guidance. Swept path analysis will be submitted as part of a planning submission. • Internal Layout – The Highway Authorities comments on the internal layout will be considered by the design team. In terms of Heritage, the issue to be discussed was setting of the listed building . We followed Officer’s advice and submitted a request for formal conservation pre-application advice, however the Conservation Officer has since advised that they would not comment on such a submission. We have sought further direction from Planning Officers, a response is awaited. The consultant team has prepared a further update to their reports as part of the evidence base and this is included as part of the Call for Sites submission.Long Itchington is a small scale residential opportunity that is able to contribute to a 5 year housing land supply. It is not strategic in scale, however it can make a contribution towards 5 year housing land supply whilst strategic sites are worked through. In our view there is a need for the SWLP to consider housing land supply in this context and the approach of preparing a Part 1 and Part 2 plans and what this means for the housing trajectory, achieving sustainable growth and meeting housing need . In our view Part 2 should be prepared in tandem, or there should be the allocation of smaller ‘non strategic’ sites or a policy approach that facilitates early delivery to maintain supply. These representations therefore consider the growth options in this context and the assessment of the site in the evidence base. The required Form has been completed on the Consultation Portal. An updated ‘call for sites’ submission accompanies this representation. Proposed Approach to Online Form and Consultation Portal We have completed the Online Forms on the SWLP Consultation Portal for the site as requested by the Council. However the Online Form is overly restrictive. For questions which require an option to be chosen, there is not always an opportunity to pick neither option. Therefore, we have artificially selected options in order to register an interest to comment, whilst cancelling out these choices, our detailed comments are set out in the covering letter below and we request that that they are considered by Officer’s in full, as well as the enclosures listed. In order to submit an answer to Question Q-S8.1, the Online Form requires you to pick an answer from the options provided for Q-S8.2. There is no opportunity to provide another answer or written comments. We have had to provide an answer however it does not represent our detailed comments set out in this letter below and we request that these comments are considered instead. Whilst we appreciate the Council’s desire to gather quantitative data, we would suggest that there needs to be the option to provide additional commentary otherwise the results of the consultation are not representative.