Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire
I am writing to share my opposed views to the proposed SWLP sites for more housing on green belt land in North Leamington Area. This is something I am strongly opposed to for a number of reasons as stated below, in no particular order of importance. *green belt land needs protecting *we need to encourage the recycling of derelict and other urban land. *green belt near north Leamington provides important spaces for people of all ages to exercise and support positive mental health. *importance of saving farmland. Important for the contribution to sustainability and security of food supply, which this land currently supplies. *importance of preserving setting and special character of historic towns, preventing neighbouring towns to merge into one. *the area also provide recreational, educational and health benefits to those in surrounding urban and suburban areas which are important now more than ever. *more housing in the area will put more pressure on already challenging road net works, access to Leamington and Warwick. Please add this to the information for opposing the building of homes on Green belt land in North Leamington area.
Option S2-C: Intensification 15. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Rosconn Strategic Land consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 16. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided. 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? 43. Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Rosconn Strategic Land agree that a threshold approach would be appropriate for any settlement listed not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66. 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? 44. Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the size and availability of suitable land identified. Stratford-on-Avon District Council has already identified suitable and sustainable sites for allocation as part of its emerging SAP. Therefore, the threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.
Q-S5.2 – Do you think the new settlements should be part of the overall strategy? New settlements that require a complete infrastructure package will take several years to deliver following adoption of the SWLP. They must, therefore, be supplemented by other allocations, especially for the early delivery of new homes. BDW’s land interest at Bishop’s Itching is deliverable in the short term. As detailed in our Call for Site submission, it can provide between 350 – 300 homes, all of which could be delivered within 5 years of the adoption of the plan. Part of the site has previously been identified as a Reserve Housing Site by the Site Allocations DPD, confirming that the Council have previously considered the site to be a suitable location for residential development. Q-S8.1 – For the settlements that fall outside the chosen growth strategy, do you think a threshold approach is appropriate to allow more small scale development to come forward? No. There are a number of settlements that fall outside of all of the identified growth strategies, with the exception of disbursed strategy, that should accommodate some development to provide for their needs. For example, Bishop’s Itchington has a relatively large population (in excess of 2,000 people) and a variety of services and facilities. Allowing infilling development only, or a threshold approach with a cap, would not meet the growth requirements of the settlement. The suggested limited 10 dwellings per site is arbitrary, it would mean that all qualifying sites fell below the affordable housing threshold stifling affordable housing delivery. The SWLP needs to ensure that an appropriate amount of development is directed towards the settlements throughout the plan area to support their growth. Q-S9 – Settlement Boundary Options 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. If reviewing the settlement boundaries is delayed until the part two plan it will stifle housing delivery in sustainable locations to the detriment of the plan’s strategy. As a consequence, any part one plan should clearly indicate the settlements that will be expected to accommodate additional growth and a broad indication of the level of the growth.
Q-S5.2 – Do you think the new settlements should be part of the overall strategy? New settlements that require a complete infrastructure package will take several years to deliver following adoption of the SWLP. They must, therefore, be supplemented by other allocations, especially for the early delivery of new homes. It is noted most of the new settlements are located on rail corridors, but mostly not in the vicinity of existing stations. It would make sense for development adjacent to existing train stations to be considered first as these are much more likely to deliver sustainable developments within the SMLP plan Period. An example the site in which BDW has an interest at Bearley. Q-S8.1 – For the settlements that fall outside the chosen growth strategy, do you think a threshold approach is appropriate to allow more small scale development to come forward? No. There are a number of settlements that fall outside the identified Growth Options, with the exception of disbursed strategy. These should be capable of accommodating development relevant to their needs. This should be based on a case-by-case basis.
Growth opportunities in the Green belt should be limited to the development of infill sites and the revision of village boundaries to take account of the existing built environment. To illustrate the potential for growth, we propose moving the Kingswood village boundary as shown on the attached plan no. 29 from the Warwick Local Plan 2011-1019 adopted 2017. The land we proposed to be included in the BUAB is of the same character as what is already included within the BUAB i.e. land which is already built upon and a very different character to the green fields beyond taking into account the urban grain and character of the built up area of Kingswood. The following facts support the proposal. 1. There is a footpath on the north side of the B4439 that extends eastwards beyond the canal bridge over the Grand Union past the Navigation car park and past Clinton House and turns into the bridleway that is part of the designated Heart of England Way which we propose should define the new boundary. 2. The footpath is lit eastwards beyond the entrance to Clinton House. 3. From the new boundary it is a 12 minute walk to Lapworth station on the Chiltern Line. 4. Kingswood is served by three bus routes, nos. 511, 513 and 514, each of which travel along the B4439 and stop adjacent to Station Lane on the B4439 in the village centre. 5. The distance to the shops in the village centre comprising a general store, post office, off-licence, hairdresser, car workshop and garage is approximately 300m. The village also has a primary school and a medical practice with 3 GPs. 6. The position of the 30mph speed limit is currently shown on the attached plan, being just within the proposed boundary. By reference to the Stratford Site Allocation Plan and the methodology used to decide what should be included within the BUAB the proposal meets the criteria, see page 318 of the document. See link https://www.stratford.gov.uk/doc/209801/name/Composite%20version%20v3.pdf In conclusion, by making a limited and judicious adjustment to the village boundary it opens up potential development sites that could accommodate growth shown in hatching on the attached plan.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
INTRODUCTION 1.1 Barton Willmore, now Stantec, is instructed by the Church Commissioners for England (‘The Church Commissioners’) to prepare a representation to the South Warwickshire Issues and Options (Regulation 18) Consultation (‘the Local Plan’), including relevant documents within the evidence base. 1.2 This Representation follows the structure of the Local Plan and seeks to respond to the questions posed within the document, where relevant. 1.3 The Church Commissioners have an interest at Land north of Long Marston Airfield, Stratfordupon-Avon, which has previously been submitted as part of the Scoping and first Call for Sites Consultation, which took place between May-June 2021 (Site Ref. ID 333: ‘Land North of Long Marston’). 1.4 Prior to this, the Church Commissioners submitted representations to the Stratford-upon-Avon Strategic Housing Land Availability Assessments (SHLAA) in 2017 and 2018 as site reference LSL.18 – ‘West of Campden Road, Long Marston in the 2019 SHLAA’. 1.5 We are continuing to promote the Site on behalf of the Church Commissioners for allocation in the new South Warwickshire Local Plan Part 1. 1.6 The following supports documents are appended to this Representation: • Vision Document, including Concept Masterplan (Appendix 1) • Highways Note (Appendix 2) • Sustainability Appraisal Review (Appendix 3) 1.7 Land North of Long Marston Airfield has capacity to deliver a strategic residential-led development for up to 2,800 dwellings, including a new primary school, nursery, health centre, extra care facility, retail and community facilities, sports facilities, public open space and other supporting infrastructure, such as mobility hubs. 1.8 This development would form an extension to, and be amalgamated with, the existing Long Marston Airfield Garden Village, which has previously been allocated for a new settlement comprising 3,500 dwellings (2,100 to be delivered within the plan period) with associated infrastructure, services and facilities including new schools, a local centre, open space and recreation provision, and a potential new railway station. 1.9 The Church Commissioners welcomes the opportunity to provide a response to the Local Plan consultation and looks forward to engaging with the Council further in respect of residential matters within South Warwickshire. LAND NORTH OF LONG MARSTON AIRFIELD Site Description and Context Site Description 11.1 The Site measures approximately 138 hectares in size and is located immediately north of the existing allocation at Long Marston Airfield Garden Village. The land and buildings are currently in use as a commercial arable farm. The Site is under the single ownership of the Church Commissioners. 11.2 Current access to the Site is via a lane that crosses east-west, with access points from both the eastern and western boundaries. 11.3 The Site is relatively flat and is understood to be largely free of any significant physical and environmental constraints to future development 4. 11.4 There are no Public Rights of Way (PRoW) running across the Site. Context 11.5 The Site is bound by agricultural land to the north, east and west with associated individual farm buildings (and small scale residential development at Willicote Pastures to the southeast). 11.6 The Site is located nearby the existing villages of Long Marston, Welford-Upon-Avon, Clifford Chambers and Quinton, and approximately 5 miles south-west of Stratford-upon-Avon town. Accordingly, there are a range of services and facilities across each of these settlements, including primary schools, medical centres, post offices, convenience stores, and pubs/ restaurants. 11.7 In addition to existing services, the Site would benefit from being in proximity to services and facilities at Long Marston Airfield Garden Village, including employment land (including a business park), a village centre comprising a range of uses, primary schools, a secondary school, and open space, including parks and amenity space. 11.8 There are several PRoWs in the local area, including surrounding villages, which provide opportunities for wider connections. 11.9 The Site benefits from being well located with regards to transport connectivity. There is an existing bus stop adjacent to Willicote Pastures on Campden Road (B4632) to the east of the Site. This provides access to several bus services (numbers 1, 1A, 2, 2A, 3, and 3A) which link Stratford-upon-Avon to Moreton-in-Marsh. These services run from approximately 7am to 7.30pm, twice an hour, with a slightly reduced service on the weekend and Bank Holidays. 11.10 Stratford-upon-Avon railway station is approximately 5.5 miles from the Site by road, or 4.5 miles via the Greenway, and provides sheltered cycle storage. The station provides frequent connection to a number of key destinations such as Birmingham (2 trains an hour on a weekday) and (via Warwick Parkway or Leamington Spa) to London (2 trains an hour on a weekday) 5. Honeybourne railway station is approximately 7miles south-west of the Site via road and is served by one/ two trains every two hours to London Paddington via Oxford and Reading and a similar frequency of services to Hereford via Worcester. 11.11 The Site is approximately 20 miles from Junction 15 of the M40. This provides connectivity to the strategic highway network. 11.12 As set out in this section, there are several accessible sustainable transport options to local and national destinations. Long Marston Airfield Garden Village 11.13 The Site is directly adjacent to the Long Marston Airfield Garden Village, which is allocated within the adopted Stratford-on-Avon Core Strategy for 3,500 new homes, of which 2,100 are to be delivered within the Plan Period to 2031. 11.14 Of these, 400 dwellings are currently being constructed, having been granted planning permission in 2017. Outline planning application ref: 18/01892/OUT for the remaining 3,100 dwellings is currently pending determination. 11.15 An opportunity exists to further extend the scope of the allocation at Long Marston Airfield through the delivery of The Church Commissioners’ Land to deliver a truly innovative and sustainable new settlement which should be explored in greater detail with the Council and relevant stakeholders. Future development on the Site would closely relate to existing proposals and would represent an appropriate pattern for further development to the meet housing needs. Constraints and Opportunities 11.16 The Site is not located in the Green Belt or the Cotswolds Area of Outstanding Natural Beauty (AONB), which lies approximately 4.5 miles to the south of the Site. The Stratford-on-Avon Core Strategy (adopted July 2016) notes that although views across the Garden Village are afforded from the top of Meon Hill to the south (within the AONB), those from public vantage points, including PRoWs are limited. Whilst specialist landscape work will be required to assess any implications in respect of this Site, it is considered that views are likely to be similar or perhaps less apparent given the Site is to the north of the Garden Village. It is also considered that the landscape context will change as a result of the Garden Village development. 11.17 The majority of the Site is located within Flood Zone 1 with the exception of a limited area of land which falls within Flood Zone 3 in the vicinity of Marchfont Brook which runs along the northern and eastern edges of the Site, and Gran Brook which forms part of the western boundary. No built development is proposed in Flood Zone 3 and instead the development elsewhere will provide opportunities for both Blue and Green Infrastructure enhancements. 11.18 The Site is not subject to any statutory environmental or heritage asset designations. The closest heritage asset is the Grade II listed Wincote Farmhouse which lies approximately 900 metres to the southeast. There are trees and hedgerows on the Site, however these are not considered to be substantial relative to the scale of the Site. 11.19 The Long Marston Greenway runs along the western edge of the Site and provides a pedestrian/ cycle connection with the PRoW network and to Stratford-upon-Avon. It is an approximately 20 minute bike ride to Stratford-upon-Avon from the Site, although it has been previously proposed to re-open the Stratford-Honeybourne Railway Line along with route. Concept Plan • Several iterations of a Concept Plan are included within the Vision Document at Appendix 1 to this Representation, to demonstrate the potential development of the Site. 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 2,800 dwellings • Land for: a) A new 2FE/3FE primary school b) A nursery c) health centre d) extra care facility e) retail and community facilities f) sports facilities g) public open space and h) other supporting infrastructure, such as mobility hubs. • The proposed development seeks to retains the existing hedgerow field pattern. An integrated sustainable drainage strategy utilities existing landscape features along with the Site’s topography to create blue and green corridors, infrastructure, and SuDS areas, most notably to the west of the Site. • Vehicular access from Campden Road (B4632) to the east, with clearly defined routes going westwards through the Site. • Enhancement of surrounding PRoWs and pedestrian/ cycle connections, most notably the Greenway, with an emphasis on linking the Site to the local movement network. • An average density similar to that of the adjacent Airfield proposals has been applied; 35 dwellings per hectare for the developable area, which equates to around 20 dwellings per hectare when the various open space and envisaged SuDS infrastructure etc are incorporated. Applying these principles has led to an indicative capacity of approximately 2,800 dwellings. Highways and Access Access Strategy 11.20 There are no third-party constraints to accessing the Site. The proposed Site access is located on the eastern boundary, off Campden Road (B4632). This is a suitable access point for the development proposed, with a reduced 50mph speed restriction already in place at the point of the proposed site access. Cycling and Walking Strategy 11.21 The Site benefits from being well-located to pedestrian and cycle facilities, most notably the Greenway to the west. This provides local access to nearby villages in addition to Stratfordupon-Avon. It is proposed to connect to these facilities and seek to enhance them where possible. In addition, it is proposed to provide pedestrian/ cycle infrastructure within the Site to encourage use and alleviate any safety concerns. Public Transport Strategy 11.22 As set out above and identified in the Vision Document, the Site is well located with regards to transport connectivity. This includes local bus routes via existing bus routes on Campden Road (B4632) and proximity to Stratford-upon-Avon and Honeybourne train stations. 11.23 We would welcome future discussions with the appropriate stakeholders to agree a strategy to integrate into the local transport network to provide the best possible links for existing and future residents. Flooding and Drainage 11.24 The proposed development, as shown on the Concept Plan, currently proposes no built form in parts of the Site affected by Flood Zone 3. Green-blue infrastructure corridors are proposed to manage surface water flows, providing a connection to the Brooks to the north and west of the Site. This will, inter alia, ensure the sustainable management of surface water, enrich biodiversity, provide amenity value, and enhance water quality throughout the development. 11.25 Furthermore, sustainable drainage systems will be implemented in areas affected by Flood Zone 3 in order to limit surface water flows in addition to providing multifunctional benefits, including green-blue corridors, public open space, and attenuation areas. 11.26 Further technical work in respect of flooding and drainage will be carried out in due course and shared with the Council when finalised. Open Space Network 11.27 As set out within the Vision Document, it is proposed that the Site be divided into separate components through the use of green corridors/ fingers. These will provide pedestrian and cycle routes through the Site connecting to existing connections such as the Greenway, in addition to the adjacent Garden Village development to the south. These are also proposed to accommodate SuDs features, playing fields and significant tree planting, seeking to retain existing trees and hedgerows where possible. 11.28 The majority of the open space is proposed is concentrated on the western part of the Site to create a linear green corridor/ park adjacent to the Greenway. Summary 11.29 This representation has been prepared by Barton Willmore, now Stantec, on behalf of The Church Commissioners for England, in response to the South Warwickshire Local Plan Part 1 consultation. Following the initial promotion of Land North of Long Marston Airfield through 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. 11.30 The Site is not located in the Green Belt and consequently, there would be no need to argue very special circumstances to justify its development.. The Site is in single ownership and can come forward immediately. 11.31 The Site is capable of delivering approximately 2,800 dwellings based on a similar density strategy to the adjoining Long Marston Airfield Garden Village to the south. The Site’s proposed access is off Campden Road (B4632) and will also seek to include pedestrian and cycle route provision (both within the Site itself) and to connect with the surrounding area including the Greenway, public open space, and SuDS areas. 11.32 The Site is in a sustainable location, directly adjoining the Garden Village to the south which is currently being built out. It is proposed to utilise services and facilities coming forward as part of this development in part, whilst also providing a range of its own amenities and services. 11.33 In line with both Planning Practice Guidance and the NPPF, the Site is deliverable due to it being: • Suitable for development – the Site has no constraints which restrict its development. Whilst parts of the Site are in Flood Zone 3, this has been considered when developing an initial Concept Masterplan. • Available and achievable for development – the Site is within single ownership and can come forward immediately, certainly the first part of the plan period, at least in part due to the potential large scale. In addition, a robust framework could enable the site to come forward holistically alongside adjacent landowners if required.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
Q-S5.2 – Do you think the new settlements should be part of the overall strategy? New settlements that require a complete infrastructure package will, in all likelihood, take at least several years from the adopted of the SWLP to start to deliver housing. They must, therefore, be supplemented by other allocations. It is noted most of the new settlements are located on rail corridors and mainly not in the vicinity of existing stations. It would make more sense for development adjacent to existing train stations to be considered first as these are much more likely to deliver sustainable developments within the SMLP plan Period. Such a site is the land in which BDW has an interest at Wilmcote. The site is also of sufficient size to provide a primary school, employment land and significant areas of open space. Q-S8.1 – For the settlements that fall outside the chosen growth strategy, do you think a threshold approach is appropriate to allow more small scale development to come forward? No. There are a number of settlements that fall outside the identified Growth Options, with the exception of disbursed strategy. These should be capable of accommodating development relevant to their needs. This should be based on a case-by-case basis.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
Q-S1: Please select the option which is most appropriate for South Warwickshire? The Church Commissioners supports the concept presented 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 will also ensure that the identified corridors and growth strategy do not conflict with one another. Furthermore, including these corridors within the Local Plan also ensures that they are appropriately consulted upon against the statutory tests for plan-making, whereas this would not be the case within the Local Nature Recovery Strategy. 3.16 The Church Commissioners reserves the right to comment upon any Strategic Green and Blue Corridors identified within future iterations of the Plan. Any such corridors such be based on proportionate evidence, including in respect of their delivery. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Given the clear deficiency in the supply of brownfield land identified above in response to Question S3.1, The Church Commissioners strongly believes Option S3.c should be followed. This is not to say that The Church Commissioners does not support the redevelopment of brownfield land, but the lack of available supply evidence through the Urban Growth Study is clearly acute, with the Study concluding that ’…it is unlikely to be possible to meet current development needs without significant greenfield development.’ 3.21 It would therefore be inappropriate to ‘prioritise’ brownfield land ahead of developing other sustainable greenfield sites. This would result in an artificially constrained supply of housing, particularly at the start of the Plan Period, restricting the ability of both Councils to be able to demonstrate a five-year housing land supply, as required by National Policy. 3.22 Alternatively, brownfield and greenfield land should be brought forward coherently as part of a comprehensive growth strategy. Q-S5.2: Do you think new settlements should be part of the overall strategy? 3.25 The Church Commissioners supports the provision of new settlements as part of an overall growth strategy and submits that Land North of Long Marston Airfield (Location Reference: E1) should be allocated for development. 3.26 Table 6 summarises the potential locations for a new settlement, including any overarching constraints. It is clear from this Table that Land North of Long Marston Airfield (Location Reference: E1) is subject to fewer constraints than other alternatives; it is not Green Belt, Conservation Area, Special Landscape Area, Ancient Woodland or SSSI. 3.27 However, the Church Commissioners dispute the assertion that development at Long Marston Airfield would be dependent on the provision of a new railway station and line. The Highways Note at Appendix 2 to this Representation sets out how the utilisation of the existing Greenway serves as a traffic free route into Stratford. 3.28 Similarly, the Church Commissioners dispute the assertion that the development of the Site would result in coalescence with existing settlements. The northern boundary of the Site is approximately 3.75km from the southern edge of Stratford-upon-Avon, ‘as the crow flies’. There would accordingly remain a clear distinction between these settlements.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
Issue S2: Intensification: There are compelling reasons to have strong policies to support increasing active travel (cycling and walking), maintaining and improving public transport and local services and reducing the need to build on greenfield sites. Issue S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites. Issue S6: A review of Green Belt boundaries: The purpose of Green Belt designation as set out in national policy is to prevent the sprawl of built-up areas and neighbouring towns merging. Additionally, the designation helps safeguard the countryside, and preserves the setting and special character of historic towns, with focus to be placed on brownfield sites instead. It is difficult to see how a change in Green Belt boundaries is compatible with any of these objectives. Further comments: Serious concerns on building in areas near the historic castle and the local nature reserves of parliament piece.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
QS4.1 Growth of existing settlements - Growth of existing settlements should only be considered where it does not require development in the greenbelt. The extension of existing settlements in non- greenbelt locations has been successful in the past and should remain the priority, together with associated investment in infrastructure. Where this approach cannot be achieved, alternative solutions should be sought that do not involve development on greenbelt land. Q-S5.2 - New Settlements: It is wholly unacceptable to consider the development of a new settlement on greenbelt land as there are no exceptional circumstances that would justify doing so. It is therefore unacceptable to consider multiple new locations for settlements, as shown in the current consultation document, which run counter to the NPPF principles. If a new settlement is to be considered, this should only be on non-greenbelt land, as there are ample non-greenbelt options for new settlements. New infrastructure can be developed to support non-greenbelt sites and this is also likely to be easier to deliver, because of its likely proximity to existing infrastructure. Q-S5.3 - Rall Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. Development alongside rail corridors to the South of the region, avoiding greenbelt development should be supported. The plan indicates that an indicative 6,000 new homes would be sufficient to support a new rail station and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overloading existing areas/stations. For example, it would be Inappropriate to expect those living in new developments in North Leamington to use Leamington Spa station, because there is already heavy traffic congestion around this station, some of which is already caused by people travelling from the North to the South of the town. The Climate Emergency must not be used as justification to develop on greenbelt land, because this is not only a weak argument, but counter-productive, because not only are there other ways of mitigating the causes of the climate emergency without developing on greenbelt land, but because preservation of the greenbelt, especially for farming, makes a positive contribution to offsetting climate change. Q-S7.2 - Dispersed Development -For the remaining spatial growth options, it is important to give priority to avoiding development on greenbelt land. Any greenbelt development in each spatial option should be carefully considered before selecting a specific spatial growth option in order to fulfil the NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering whether this involves development on greenbelt in order to deliver that option. Instead, other spatial growth options should be selected that require less (or no) greenbelt development and the option with the least greenbelt development should be selected, even if more new infrastructure is needed. Retrospectively claiming 'exceptional circumstances' apply, because there is no other way to meet a selected spatial growth option, is therefore obviously unacceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: A threshold approach to small scale development is inappropriate in greenbelt areas, nor should the plan allow for more small-scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. As mentioned above, this is a fallacious argument, because preservation of the greenbelt contributes positively to reducing the impacts of climate change. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries, especially when this can be used as a means of permitting development in what would have otherwise been greenbelt This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can In no way be considered representative of the population. Given the very small number of respondents, is it possible that these were from developers or others who would benefit from such development, as I note that there were almost as many sites submitted as responses received? The tiny number of respondents should therefore not be used as a basis for decision making and should not be used to justify development or a review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
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-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S7.2 - For the remaining spatial growth options, I feel it is important that the priority is to avoid developing greenbelt land. The need for greenbelt development in each spatial option should be considered before selecting a specific spatial growth option. This is needed to fulfil NPPF "exceptional circumstances" principle. It is not acceptable to select a spatial option without first considering the need to develop greenbelt to deliver that option. Instead, it should be assessed whether another spatial growth option could be selected that requires less (or no) greenbelt development, and that option with the least greenbelt development should be selected, even if more infrastructure work is needed. Retrospectively claiming exceptional circumstances are needed because there is no other way to meet a selected spatial growth option is not acceptable. The climate emergency should not be used as a justification to develop greenbelt land. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
Q S.1 The Parish Council considers Options S1a and S1b Corridors will be unhealthy channelling of expansion and should be avoided. It will put undue pressure on a few areas. Q.S.2 The Parish Council does not advance or promote any sites for any form of development. We would question the emphasis places on the 'call for sites'. There is now more than enough land with planning permission. The consultation volume does not give the figures for Warwick and Stratford Districts for permissions which have not started construction; existing permissions should be used before any further development is considered. The large number of unimplemented permissions for new build development indicates that the housing permitted is not actually required, and is more use to developers as undeveloped land with permission (land banks), assets that enable them to increase company value and share price. QS8.1 QS8.2 Outside the settlements the Countryside Policy should prevail. Inside the settlements the size should be in accordance with the Neighbourhood Plan and/or Village Design Statement and appropriate to the nature of the specific sites QS.10 Unless the chosen option presents sound proposals to deal with these issues in the early years of the plan none of the growth options will be acceptable.
I am one of the 3 Leamington Milverton District Councillors and am emailing about the consideration of a review of Green Belt boundaries as outlined in the Issues and Options Consultation on the South Warwickshire Local Plan. My concern is for the Green Belt around the north of Leamington, which appears to me to fulfil all the 5 stated purposes of a Green Belt. It is in addition high quality agricultural land, crossed by footpaths which are extremely well used by local residents for recreation. More importantly it acts as a defining space between Leamington and Old Milverton, Leamington and Blackdown, and Leamington and Kenilworth preserving the distinct identities of each. 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).
I wish to offer the following reasons for protecting the green belt: Prevent Urban Sprawl. Green belt purpose is to prevent urban sprawl in this case between Leamington and Kenilworth. The area between North Leamington and Kenilworth covering Old Milverton, Blackdown, Hill Wooton and Ashow is outstandingly beautiful and provides wonderful opportunities for walkers. Recreation and Physical and Mental Health. Development in the green belt would destroy for ever its recreational opportunities and have a serious impact on the physical and mental well- being of residents and visitors. A footpath through a housing estate does not compare with one across fields. Safeguard the area for future generations. There seems to be a presumption in the S Warwickshire plan for building in the green belt instead of protecting it. Development in the green belt would destroy for ever one of the principal reasons that people have for valuing Leamington as a desirable place to live, work and enjoy. There are no exceptional reasons for building in the green belt and housing development in the south of Leamington and Warwick is more than adequate.
1. Introduction 1.1 About Copperfield 1.1.1 Copperfield Land and Planning Land Limited are a specialist Town Planning Consultancy based in Bristol. The business focuses on providing planning advice to a wide range of clients in the South West and Midlands including assessments relating to sustainability, master planning and spatial planning policy matters. 1.1.2 Copperfield have previously submitted representations on behalf of St. Modwen during 2021 and 2022 relating to previous stages of the South Warwickshire Local Plan and Call for Sites. 1.2 About St. Modwen 1.2.1 St. Modwen are a highly successful land promoter and housebuilder who specialise in the delivery of large scale sustainable development solutions and mixed use regeneration projects. They are currently the lead master developer of high quality sustainable new community at the Meon Vale development in Stratford upon Avon. 1.2.2 St. Modwen have an interest in land to the East of Southam and are engaged in the long term promotion of the site. It is intended to promote the land through the newly formed South Warwickshire Local Plan by working with the combined authority planning team and other local community stakeholders to deliver a successful large scale sustainable housing led development for the town. 1.3 Scope of this Representation 1.3.1 This representation seeks to promote the Town of Southam and particularly land to the east as a sustainable location for new growth within the new South Warwickshire Local Plan area. Within the context of growth for the town the appended Vision Document also seeks to identify the development potential and opportunity value for land to the East of the town. 1.3.2 Section 2 of this report sets out some high level principles and the sustainable development focus for the land within control of St. Modwen. It incorporates a range of potential land uses to form a sustainable new suburb supporting the long term vitality of the existing town centre and providing development of sufficient quantum to provide key social and physical infrastructure. This report also sets out a delivery timetable for the development providing clarity on the potential of the site within the plan period. 1.3.3 Section 3 of the report sets out Southam’s role within the current Local Plan for Stratford upon Avon and its emerging role within the new South Warwickshire Local Plan. This section establishes the importance of the town to the District, its residents and the surrounding rural areas who rely upon Southam as a service centre. 1.3.4 Section 4 takes a more detailed look at Southam as a sustainable settlement and its ability to accommodate growth. The section sets out why the land to the East of the town should be considered favourably for new development when considering the emerging policy objectives and evidence base of the new Local Plan. Section 5 of the report responds to the SWLP Consultation document Issues as they relate to Southam as a settlement and land to the east of Southam as a preferred Broad Location. St. Modwen’s representation are highlighted and 17 sections of the SWLP Issues and Options document assessed. 1.3.6 Section 6 sets out broad conclusions from our assessment of the Issues and Options consultation document. 2. About Land East of Southam 2.1 Location 2.1.1 The 98.7Ha site is located to the east of the rural market town of Southam and is shown outlined in red in the plan below. 2.1.2 It comprises principally agricultural fields used for arable crops. Fields are generally bounded by hedgerows. The Site is bounded to the north and to the south east by the A425 Daventry Road and Welsh Road East respectively. The River Stowe bounds part of the Site to the east. Beyond these linear boundaries is open countryside. To the west the Site is bounded by modern residential development at Flying Fields and the town of Southam. 2.2 Master Planning Principles 2.2.1 A team of technical specialists have been developing a Masterplan Vision Document and a short version has been submitted alongside this representation to set out the ambitions for the project. The vision document is appended to this representation document. 2.2.2 The site initial concepts offer the following key features: A mix of high quality housing, including affordable housing and potential for later years provision, responding to local need; • A new Country Park accessible by foot and cycle providing access to green spaces, formal and informal sports and play and enhanced biodiversity Infrastructure; • S.106 and CIL funding for education provision including a primary school and land for a potential secondary school (or other uses); • Social infrastructure including potential convenience, retail, remote working facility, and space for GP or dental provision within a neighbourhood centre; • Employment opportunities through construction phase and through the provision of mixed use communities including employment opportunities on the development; • An extension to the existing community well integrated through sustainable access routes; • Economic benefits including council tax income and additional spend on local businesses generated by the new residents; • Enhanced connectivity opportunities via the existing gateways into the east of the town with public transport access and dedicated pedestrian and cycle networks. The site has the potential to deliver a balanced communities solution for Southam supporting the town centre and other local services, delivering up to 2000 new market and affordable homes with sustainability and carbon reduction as a key feature of the new community. 2.3 Delivery in the Plan Period 2.3.1 The 2018 Letwin Review was a Government commissioned Independent Review of Build Out on major large scale housing schemes. Letwin’s report was presented to parliament in October 2018 to establish whether land banking within the industry was occurring. 2.3.2 His analysis focused on the issue of the build out rate of fully permitted new homes on the largest sites in areas of high housing demand. Approximately 92 sites of over 1,500 dwellings were reviewed with an average site size of 3,327 new homes. Data found that the average length of the build out was 15.5 years equating to an average large site size delivery of 214 homes per annum. Letwin excluded periods of enabling works and planning promotion or application periods in this assessment. 2.3.3 Further research on the enabling of large site delivery was captured in Lichfields ‘Start to Finish’ 2020 Report documenting the challenges of consenting, enabling and delivering large scale housing schemes. The report highlighted that from the date at which an outline application is validated, the average figures can be 5.0-8.4 years for the first home to be delivered; 2.3.4 St. Modwen as master developer with a demonstrable track record of delivery of major mixed use development schemes within Stratford Upon Avon District (Meon Vale Development) are ideally placed to deliver higher levels of development on schemes of this nature. The table below shows how the master developer approach could deliver significant benefits through the plan period using a 3 housebuilder build out model. A LDO process could be used if supported by the Local Authority as this could speed up delivery. 3. Southam in the Issues and Option Consultation 3.1 Southam’s current role in Stratford on Avon Local Plan 3.1.1 Southam is a market town located in the north-east of Stratford-on-Avon District, about six miles to the east of Leamington Spa. It has a population of 6,567 (Census 2011 data). 3.1.2 The A423 runs through Southam, connecting the market town to Coventry in the north and Banbury in the South. Access to the M40 at Gaydon is located only 5 miles to the south and the town is strategically well located for commuting to the major Conurbations in the West Midlands. The town expanded considerably between 1961 and 1971 and more recently between 1980 to 2008. The latest allocated sites are also being delivered with a further 1000 dwellings being constructed in the current plan period. Development locations have been influenced by the introduction of the A423 Southam Bypass constructed in 1992. Most development is located to the west of the A423 and it is only in the last plan period that large scale residential development of any size has moved out to the east. 3.1.3 The town has a conservation area at its core including the town centre retail space. Out of town convenience in the form of a Tesco superstore has been built on the SW of the town on the A425 Leamington Road. The town is also well provisioned with a good employment base centred around the larger Industrial buildings which are located in the south of the town. 3.1.4 The Core Strategy 2011-31 vision for Southam states that it will continue to prosper as a centre and focal point for shops, services and jobs for a sizeable rural catchment. Development will have taken place to the north, east and south of the town to provide significant numbers of new homes, a range of new sports facilities and other community infrastructure, and about 3 hectares of additional employment land. In 2011 Southam had a population of 6,567 people and with growth in the last 10 years this is now grown to 8,114 people. 3.1.5 The Stratford-on-Avon Core Strategy classes Southam as a Main Rural Centre that functions as a service centre for large parts of the eastern section of the district. It is noted that it provides essential facilities for the surrounding rural area. 3.1.6 Within the 2015 Core Strategy the Local Authority noted the following potential future growth issues and opportunities for Southam: Southam’s character as a rural market town needs to be protected; Development to the east of the bypass would tend to exacerbate the issues of severance and integration that has been experienced with large housing estates built in the 1990s; If any development is to be acceptable to the east this area, high quality crossings of the bypass for pedestrians and cyclists will be essential in order to provide attractive links to the town centre, schools and various facilities; Landscape Sensitivity Study identifies much of this area to the east as being of only medium value in terms of impact from housing development; Land on the southern edge of the town is of medium landscape value; The sloping and elevated land relating to the Stowe Valley on the west side of the town is particularly sensitive in landscape terms and would impinge on what remains of the open aspect of this part of the town’s setting; The Stowe Valley area is designated as an Area of Restraint. The Landscape Sensitivity Study identifies the entire western flank of the town as high/medium value; None of the land on the periphery of Southam is of high quality agricultural value; There are a number of specific ecological and archaeological features that need to be taken into account, including some of the best surviving ridge and furrow in the area; There is also an extensive Conservation Area covering the central part of the town and the open space to the west of the town centre; There is a mineral safeguarding area to the north east of the town, beyond the bypass; The cutting sides of the bypass at its northern end, and the quarry associated with Southam Cement Works, are designated as Regionally Important Geological Sites; Further large-scale development proposals in the town will be dependant on additional capacity being provided at the Itchen Bank Wastewater Treatment Works. This will require the involvement of Severn Trent Water; The River Stowe valley through Southam to its confluence with River Itchen lies within Flood Zone 3a; The route of the proposed High Speed Two railway runs close to the southern edge of the town; The employment land study resisted major employment growth unless major housing is proposed but noted the provision of small business floorspace on existing sites should be encouraged; The town centre needs to be improved through a wide range of measures to improve its economic viability and physical appearance; The Policy AS7 records the need to improve formal sports pitch provision and improved pedestrian links to the town centre. 4 The Local Plan also sets out aspirational objectives for the built environment and setting of Southam which its states will have been enhanced, including by restraining development in the Stowe Valley to the west of the town. The Local Plan allocation map is below: 3.1.5 The Core Strategy identified Southam as a sustainable location for significant growth. It looked to deliver about 1,100 homes in the market town over the plan period. Three sites were allocated for development in the Core Strategy: o Land West of Banbury Road, Southam (SOU.1): 200 homes o Land West of Coventry Road, Southam (SOU.2): 165 homes o Land South of Daventry Road, Southam (SOU.3): 530 homes 3.1.6 The HS2 line is now in construction to the south of the settlement and all three of the above allocations are being delivered. 3.2 Southam’s future role in the New South Warwickshire Local Plan 3.2.1 The emerging South Warwickshire Local Plan will replace the existing Stratford-on-Avon Core Strategy and the existing Warwick Local plan to provide a combined strategy for both districts. From 10 May to 21 June 2021, a Scoping and Call for Sites consultation was run. The consultation’s focus was to determine where future growth should be located. Seven growth options were proposed, of which four identified Southam as a potential location for future growth. There were: Growth Option B - seeks to accommodate growth along existing bus corridors Growth Option C - along main road corridors; Growth Option E - in areas with the greatest need for new homes and jobs due to higher unemployment rates, lower qualifications and high need for affordable housing based on the housing waiting list. Growth Option G - proposes to locate growth in settlements that have been identified as suitable locations for development in the existing Local Plans. 3.2.2 The feedback to this consultation has resulted in further growth options being included in the 2023 Issues and Option Consultation. Southam again plays its part in a number of these options. 3.2.3 Southam is listed under the following Growth Options in the January 2023 Issues and Options Consultation: Growth Option 3 – Economy Growth Option 4 – Economy and Sustainable Transport Growth Option 5 - Dispersed 3.2.4 Southam is excluded from Option 1 – Rail Corridors as it is not currently serviced by a railway station with the nearest services being Leamington Spa and Warwick Parkway. Southam is also excluded from Option 2 – Sustainable Travel by virtue of the lack of a dedicated railway station. 3.2.5 The South Warwickshire Issues and Option Consultation identified Southam as one of nine towns within the Local Plan area worth assessing as Broad Locations for future growth. Four Broad Locations were analysed around Southam. Settlement Analysis was undertaken to better understand growth potential in the 9 towns and 21 smaller settlements considered as potential growth locations. 3.2.6 Southam area is also recognised as part of the emerging Local Plan. “Unique Economic Assets” in the named Silicon Spa, part of the gaming industry. This extends from Leamington out to the surrounding areas of Southam and Warwick employing over 2,000 highly skilled people. 4. Southam as a Sustainable Location for Growth 4.1 Planning Policy Designations for Southam 4.1.1 The current Stratford Upon Avon Core Strategy was adopted on 11 July 2016 and includes a proposals map (see section 2.2). There are currently no environmental designations covering any of the land around Southam. 4.1.2 In other areas around the Borough there are environmental constraints including the Cotswold AONB to the south and Green Belt to the north. It is noted that the current Consultation adopts a “policy off” approach to assessing Green Belt and AONB in the context of Growth Options. 4.1.3 It should be recognised that the most significant Local Plan constraint policy for the Borough does relate to Green Belt. The current Core Strategy states that once established, Green Belt boundaries should be altered only in exceptional circumstances. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch, Bromsgrove, Solihull and Warwick. Much of the land within Option 1 and 2 Growth Options would involve the loss of significant areas of Green Belt. 4.1.4 The current extent of the approved Green Belt has been established since 1975 and the Core Strategy states that it still complies with the purposes of including land within it, as now set out in the NPPF. In the last Local Plan the Council states that there are no reasons for extending the area covered by the Green Belt within Stratford-on-Avon District. Likewise, there is no justification for making a significant reduction to the current extent of the approved Green Belt. 4.1.5 Matters relating to Green Belt are referenced in Issue S6 of the current consultation document. St. Modwen would support a Green Belt review to establish capacity within these areas as part of any future review. The review must incorporate development capacity assessments in green belt locations if it is to be successful in balancing the protection of current green belt boundaries with the sustainable development opportunities of non-green belt locations. 4.1.6 For Southam, there are very few acknowledged policy constraints to consider. Only the area to the west of the town ‘Area of Development Restraint’ and ‘HS2 Safeguarded Route” policy constraints apply. 4.2 Landscape and Environmental Designations 4.2.1 Nationally designated areas, including Areas of Outstanding Natural Beauty (AONB), have been confirmed by the Government as having the highest status of protection in relation to landscape and scenic beauty. Development will generally be restricted in these areas. 4.2.2 Southam is also located away from any Special Landscape Area Designations located at Arden, Cotswold Fringe, Feldon Parkland and Ironstone Hills Fringe.4.2.3 To the West of Southam is the Stowe Valley area, designated as an Area of Restraint. These areas make an important contribution to the character of the settlement. Development must not harm or threaten the open nature of such areas, taking into account any possible cumulative effects. Planning permission for a large-scale form of development in an Area of Restraint will only be granted where a scheme would have demonstrable community benefits and contribute significantly to meeting an objective of the Core Strategy. 4.2.4 There were 9 European recognised SAC, SPA and Ramsar sites located within 20 km of Stratford. None of these designated assets identified in the Habitat Impact Assessment were situated to the east of Stratford near to Southam. 4.2.5 The Landscape Sensitivity Analysis was undertaken in July 2011 and the extract is set out below capturing the relative sensitivities to the landscapes around Southam. Based on the above review there are relatively few environmental constraints, sensitive designations or environmental constraint restrictions on future development around Southam beyond the Stowe Valley area to the west of the Town Centre. The landscape evidence suggest less sensitive areas are located to the south and east of Southam.Heritage 4.3.1 There are no designated scheduled ancient monuments, registered battlefields or registered parks and gardens present in Southam. Archaeological studies recognise MWA 4789 as a postmedieval Turnpike Road from Ryton Bridge to Banbury via Southam. 4.3.2 There are 40 listed buildings within Southam. These are detailed in the graphic below. 4.3.3 There are generally no significant heritage assets that would preclude the sensitive and appropriate development of land around Southam. 4.4 Evidence Base – Settlement Analysis 4.4.1 The current consultation documents are supported by Settlement Analysis dated January 23. The document assesses settlement structure, constraints mapping, connectivity and local services mapping. 4.4.2 It is important to note no associated levels of growth or capacity assessment has been conducted. Large scale development provides opportunity to address existing and future impacts and provide adequate mitigation so the study work needs to be assessed within the context of small scale development only, or assessment work amended once overall levels of growth are identified. 4.4.3 Southam is assessed as a second tier settlement and scores well against its peers with the exception of rail accessibility. 4.4.4 The Connections Analysis documents includes reference to 9 assessed areas. The following observations are made: Area 9 fails to assess the edge incorporating the school playing fields which extend significantly into the countryside. For the purposes of edge analysis this should be addressed in any future study; Areas 7 and 8 are covered by current ‘Area of Development Restraint’ policy. This policy aligns with the evidence base landform analysis which annotated both areas as steeply sloped. Connectivity analysis should take account of topography where this analysis is looking at potential future connections; Area 6 is now completely bisected by HS2 rail routes which limits potential for larger scale growth and development options. Updated mapping should be used to identify if land parcels in this area are available; Within the Key of the Connections Analysis diagram it notes Public Rights of Way but not all are shown on the diagram. The Connections Analysis document also looks at access to facilities within 800m. Intelligent referencing should be made to larger scale development options which bring new or enhanced local facilities and connectivity of other facilities such as school, employment related uses and open spaces. 6. The Future for Southam – Conclusions of the Representation 6.1 Southam is a highly sustainable and generally unconstrained location for future housing growth and the significant benefits delivered by new housing growth would be of economic and social benefit to the existing residents of the town and the rural communities that Southam serves. Having reviewed the SWLP evidence base and assessed the Growth Options set out in the current consultation St. Modwen strongly believes that Southam is the right location for significant new development in the new SWLP. 6.2 The evidence base also reviews Broad Locations around Southam. Our review of this evidence and the scoring matrix contained within the Sustainability Appraisal suggest that errors have been made in the Council’s assessment. When these errors (see sections 4.4.4 and 5.5 of this representation) are corrected St. Modwen strongly believe that land to the East of Southam has the highest potential to deliver sustainable and low carbon new communities which meet the future needs of the town. Development of the scale proposed by St. Modwen will also maximise the delivery potential aligned to 20 minute neighbourhood principles. 6.3 The appended vision document also highlights how the proposed development on Land East of Southam aligns with the Strategic Objectives of the SWLP. Specifically, these are: Addressing Climate Change – Our vision for land East of Southam supports sustainable and net zero carbon ambitions to address climate change effects including through the provision of green and blue infrastructure; Promoting wellbeing – Our vision for land East of Southam will deliver on site provision of health and education facilities, along with affordable housing which St. Modwen agree is critical to the success of achieving sustainable communities. Our proposals promote healthy, inclusive and safe places and include the provision of pedestrian and cycle connections within and between neighbourhoods, high quality public space, safe and accessible green infrastructure, sport and recreation facilities, local shops, meeting places, access to healthier food and allotments. Improving connectivity – Our vision for land East of Southam will provide for appropriate transport infrastructure and consider the opportunities from existing or proposed transport infrastructure particularly those in relation to walking, cycling and public transport. Increasing biodiversity – Our vision for land East of Southam includes green and blue Infrastructure providing multiple benefits to existing and new residents of the town. These spaces will create and enhance habitats and biodiversity rich places securing measurable net gains for the development. Creating well-designed and beautiful places – Our vision for land East of Southam will be focused on design quality relating to individual buildings and the spaces and places between them including the potential for public art. St. Modwen acknowledge that a ‘policy off’ position has been taken to assessing Broad Location and New Settlements and this includes only limited Green Belt considerations. St. Modwen believes that when an assessment of the appropriateness of large scale new development in the Green Belt is undertaken, that policy unconstrained locations such as Southam should be given higher weighting as a suitable location for major growth. A Green Belt review should be prioritised ahead of any further growth strategy work to ensure that future assessment work considers all significant issues. 6.5 St. Modwen strongly agrees that any preferred Growth Strategy needs to factor in the impact of new development on the Green Belt. 6.6 On Issue H4 we believe there is further consideration of sub regional and regional housing growth. St. Modwen support the need to define the level of additional housing to allow the SWLP to proceed. 6.7 On Issue H1, St. Modwen supports the use of evidence on affordability and housing need to ensure that SWLP delivers mixed tenure development that reduces the affordability crisis, giving access to suitable housing accommodation for all existing and future residents. 6.8 A St. Modwen would highlight the following key SWLP consultation responses as they relate to directing growth to Southam. On Issue V1 – Vision for the Local Plan St. Modwen fully support the ambitions set out in the SWLP Vision Statement. On Issue V3 – Strategic Objectives St. Modwen supports the Strategic Objectives. On Issue S4 - Growth of existing settlements St. Modwen strongly support the need for sustainable urban extensions to meet the future growth needs of the SWLP as part of a balanced overall growth strategy. St. Modwen would highlight the following SWLP consultation response as they relate to Land East of Southam: On Issue I1 – Sustainability Appraisal St. Modwen questions to the conclusions of the Sustainability Appraisal for Southam. Errors have been made in the evidence base that need correcting as the SE Broad Location is the most sustainable location as supported by Table 4.1 of the Councils Sustainability Assessment. On Issue I5 – Viability and Deliverability St. Modwen strongly feel that viability and deliverability are key to achieving a successful SWLP and that land East of Southam will deliver if allocated in the Local Plan. On Issue T1 - 20-minute neighbourhoods St. Modwen supports the principle of the 20-minute neighbourhoods as a design principle. This can be delivered through comprehensive growth strategies that provide service and facilities as part of new development.