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

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

There are areas of South Warwickshire where we believe there is capacity for growth within the highways network and we would welcome an opportunity to discuss these with you further. Examples include Studley, Alcester and Bidford on Avon. We believe the area offers an opportunity for growth along the A46 corridor between Redditch and Evesham. The area has a firm basis to add to and enhance existing economies which could enable growth to come forward more quickly than delivering completely new settlements. We are aware of the Green Belt issues and concerns about flood risk in the area but would welcome an opportunity to further explore with you the possibilities the area could bring. We are keen to consider how new housing can be linked to the existing and proposed employment offer. In summary, the County Council is keen to continue to work with you as the Local Plan progresses and ensure that growth is sustainable through the provision of robust public transport and good active travel links. Expansion of existing settlements with these connections as well as some existing economic basis to reduce travel activity should be considered. In addition, we would wish to explore the opportunities to ensure the progression of the Local Plan is linked to our Joint commission work in relation to the work of the Integrated care system.

Q-S4.1: Yes. Growth of existing settlements is one of a number of important approaches, where it utilises existing and available infrastructure to support sustainable growth. Q-S5.2: Possibly. This should only be accordance with the NPPF, and robust evidence should be provided in respect to the sustainability of any new settlement and their deliverability within the plan period. Consideration should be given to landownership, delivery models and infrastructure requirements in the first instance, prior to setting out a strategic approach and action plan for each new settlement. It is very likely that they will have significant obstacles to overcome until effective delivery. Q-S8.1: No. This should be assessed on a case-by-case basis, as the quality, acceptability and sustainability of developments is not inherently based on the quantity of dwellings proposed, but the appropriate location and the detailed design and layout. Further, a threshold level may be appropriate for some settlements given their scale but may not be appropriate for other settlements. Therefore, flexibility to allow this to be taken into account should be kept. Q-S8.2: A threshold approach should not be adopted. Q-S10: The growth strategies described in Q.S7.2 include development in green belt locations. A Green Belt review should be undertaken as part of the core evidence base for the next stage of the local plan process. Growth Options 1, 2 and 4 should form the basis of future development within South Warwickshire, with Growth Option 3 being applied to a limited degree and Growth Option 5 to ensure the survival of smaller, more rural settlements. The local plan should adopt a flexible approach in terms of employment uses, so that it can account for future needs or opportunities that will best reflect market signals and requirements.

Knight Frank is instructed by Barratt David Wilson Trading Limited (the Landowners) (BDW) to submit these representations in response to the Issues and Options (Regulation 18) consultation to the South Warwickshire Local Plan. Through these representations reference is made to land at Copham’s Hill, west of the A46, Stratford upon Avon, Warwickshire (site reference ID 385) as evidence about which policy approaches are deliverable. The 2021 Call for Sites identified that the site proposed a mixed-use scheme, the reference number 385. The Housing and Economic Land Availability Assessment – Methodology (February 2022), which forms part of the council’s evidence base for the Regulation 18 consultation, sets out the methodology for the assessment of the sites submitted as part of the Call for Sites search. This representation and submission of the site supersedes any previous submission made via the Call for Sites process. In particular, the proposed uses of the site have changed, and the submission further reflects and aligns with landownership. This representation seeks to assist with positive discussions and encourages engagement between Knight Frank and South Warwickshire, particularly in relation to mutually beneficial opportunities the above-named site offers by way of accommodating a mixed-use development, ranging from residential including affordable housing, to local centre, hotel and associated infrastructure. A location plan and masterplan have been appended to this representation. Contents • The Site • Proposed development description • Local plan representations • Appendix A Site location plan • Appendix B Masterplan • Appendix C Connections plan • Appendix D Assessment of the site based on SA criteria • Appendix E Call for Sites The Site The site, measures approximately 37.36 hectares, is located to the north-west of Stratford-upon-Avon at Copham’s Hill, west of the A46 (see Appendix A). It currently comprises agricultural land, with two minor watercourses running north west to south east. The site benefits from direct access off the A46, with potential for direct public transport links to central Stratford-upon-Avon and pedestrian/cycle links (see Appendix C). Further, the site has direct access from The Ridgeway, a minor access road connecting to Alcester Road and into the town centre. The site is currently within the green belt. The Environment Agency’s flood risk map shows that the site is predominantly located within an area with a low risk of flooding (Flood Zone 1), with some areas along and around existing watercourses with a higher risk of flooding (Flood Zones 2 and 3). Proposed development description The proposed development of the site at Copham’s Hill offers potential for a mixed-use scheme with up to approximately 800 dwellings. A Vision Document will be submitted to the Council following the submission of these representations and will provide a comprehensive overview of the site’s potential for a mixed-use development in a highly sustainable location. The site is proposed to include the following (see Masterplan, Appendix B): • Residential development of up to approximately 800 dwellings (35-40 dpha) • Primary school • Hotel • Local centre • Alternative fuels / petrol station (including EV-charging) • Natural and semi natural green space • Formal play areas • Landscaping • Attenuation basin / SuDS • Pedestrian / cycle links • Bus services access

Petition against allocation of sites around the village of Hockley Heath I am writing as Ward Member for the Dorridge & Hockey Heath Ward of Solihull Metropolitan Borough Council, in relation to the call for sites launched by Warwick District and Stratford District Councils for the South Warwickshire Joint Local Development Plan that is in course of preparation. This has resulted in a number of sites being proposed for allocation by developers and landowners around the village of Hockley Heath. I am setting out below the text of a petition that has been signed by over 250 residents of my ward objecting to any allocation of sites adjacent to Hockley Heath. We the undersigned residents of Hockley Heath oppose the allocation of any of the sites around Hockley Heath in the South Warwickshire Joint Development Plan and oppose any further erosion of the green belt in that area. I am enclosing a printed list of those who have signed the online petition together with a list of the additional residents who have sent in paper objections. Please let me know if you need any further verification of this. More signatures are coming in more or less daily and can forward these later if required. I shall also be presenting a copy of this letter and petition at the Full Council of Solihull Metropolitan Borough Council on 5th April, with a request that the Council make strong representations against the allocation of any of these sites. The sites are all situate within the strategically important Green Belt which surrounds Hockley Heath and, for example, all share the key characteristics of planning policy necessary for that Green Belt designation. The village has neither the capacity nor the facilities to accept any additional development like this, bearing in mind the pressures on development already within the borough. Residents of my ward are upset and concerned about this opportunistic attempt by landowners and developers to seek change of status for any of this land and are adamantly opposed to any allocation of this land for development.

2 OVERVIEW OF THE SITE Site context and description 2.1 Coventry’s Southern Gateway is a strategic growth area and has a common boundary with the City of Coventry in the West Midlands. Whilst Coventry Gateway is located within Warwick District, its built form physically adjoins the Coventry urban area and being approximately 6.5km from Coventry City Centre the area looks to the city for both its social and economic needs. 2.2 The nearest train station is Coventry Station (approximately 2.5 miles to the north). Coventry Gateway is also served by local bus services from Coventry. Coventry Airport lies to the east of the Stoneleigh Road with the main runway lying within approximately 500m of the eastern boundary of the site. However, the airport is only open to private light aircraft traffic. The Airport is facing possible closure, given in February 2021, a joint venture partnership between Coventry City Council and The Rigby Group proposed to build a Gigafactory producing batteries for electric cars on the Coventry Airport site, if the project attracts investment and government funding. It is therefore clear that with the site being adjacent to an area of substantial change it is well placed to form part of that change and in particular benefit from substantial road infrastructure that has recently been implemented. 2.3 The site could gain access to the A45 strategic road network to the north via the newly constructed Silver Eagle Way with residential development in this location balancing the very substantial employment base on the southern side of Coventry (UK BIC, Gateway South & Middlemarch Industrial Estate), all of which are a very short distance from the site. 2.4 The site extends to approximately 50 hectares of greenfield land which comprises mainly fields enclosed by hedgerows albeit with a few properties along its eastern boundary. The site in its entirety and its immediate context is indicated in the vision document. Approximate capacity 2.5 As indicated in the accompanying Vision Document, the site is suitable for a variety of land uses. Two potential options have been put forward. 2.6 Firstly, based upon the density assumptions of the consultation and acknowledging the likely densities that could be achieved at this site, the estimated capacity of this site promotion, when taking account for the effect of constraints on net developable area for the site at this stage which has been explored through the vision document’s technical work that an estimated capacity equates to over 1000 dwellings (at 40dph with 50% of site for residential and remaining 50% for supporting facilities, green and blue infrastructure). 2.7 Secondly, an option for a new business park has been presented. The key ambition of an employment/commercial-led proposal is to set any development within a new landscape structure to ensure the delivery of high-quality development that relates well to the wider employment offer at the Coventry Gateway sites. Whilst taking account of the site constraints, ensuring a balance of green open spaces and access to the existing green network for potential users, at this stage the estimated capacity for possible commercial uses equates to approximately 23 hectares. Site constraints 2.8 The basis of analysed site constraints is incorporated into the accompanying vision document for the site (Section 3 of Vision Document) and forms the initial technical evidence base work for the site. For the avoidance of repetition, only matters that are not discussed through Vision Document are outlined, as follows: Agricultural Land Classification 2.9 The provisional Agricultural Land Classification (ALC) provides a method for assessing the quality of farmland to enable informed choices to be made about its future use within the planning system. It helps underpin the principles of sustainable development. Natural England’s Open Data Publication grades the agricultural land across the site as Grade 31. Figure 2-1 ALC Grades (ADAS & DEFRA) 1 Provisional Agricultural Land Classification (ALC) (England) | Provisional Agricultural Land Classification (ALC) (England) | Natural England Open Data Geoportal (arcgis.com) Tree Preservation Orders 2.10 There are no tree preservation orders within the site extents. Public Rights of Way 2.11 There is a public right of way from Baginton to Stoneleigh along the river corridor, that links with a wider network of public rights of way within the locality. Heritage Assets 2.12 The development site does not contain any listed buildings. 2.13 In the vicinity of the site, in Church Road there are a series of listed buildings including, Lucy Price House, Oak Farm, No. 2 Church Road and the Old Rectory, together with the Church of St John the Baptist. The Church is Grade I listed and is of 13th Century origin. It is set in an attractive church yard with numerous yew trees and an 18th Century brick wall at defines the northern boundary. These are a considerable distance from the Site, with very little or no intervisibility between the two, therefore either proposal will have a neutral effect on the heritage assets, and even if the Council concluded there were some harm to that asset, it would be less than substantial, and objectively outweighed by many public benefits. 2.14 In regard to, Scheduled Ancient Monuments, Baginton Castle and Fishponds are scheduled and located at some distance from the northern boundary of the site and does not present any overall constraint on the development of the site. Watercourses and Flood Risk 2.15 The Environment Agency’s Flood Maps for planning shows that part of the site lies immediately east of the River Sowe. The topography of the steeply sloping river valley sides ensures that although there are areas likely to be flooded to the west of the site land, it is restricted to the immediate vicinity of the river. It is not proposed that this area be developed as indicated in the vision document, the entirety of the developable site area is within Flood Zone 1. Ecology 2.16 No Sites of Importance for Nature Conservation (‘SINCs’) or Sites of Local Importance for Nature Conservation (‘SLINCs’) are identified within the site boundary. 2.17 The ecological data search undertaken on the site concluded there were no known nationally important sites (e.g., SSSI) which fall within the immediate area of the site. There are no designated sites of nature conservation importance within the site boundary. This information has informed the preparation of the Illustrative Concept Masterplan. The proposal will deliver in excess of 10% biodiversity net gain. Warwick District Council’s Local Plan Review (2012) 2.18 The adopted Key Diagram proposals map below highlights the urban areas and the extent of the Green Belt within the District boundary, there exists a concentrated extent of Green Belt land towards to the north of the district adjacent existing built-up areas. The principal component of which is south of Coventry. As indicated below, various sites were removed from the Green Belt and allocated for housing / employment in the adopted plan (see Figure 2-2). This includes the adjoining site (Ref. H19) which was previously removed from the Green Belt and is currently subject to a part planning approval. 2.19 The allocations shown in the map (Figure 2-3) shows the WDLP Allocations that were previously released from the Green Belt and is allocated as part of policy DS11 [Allocated Housing Sites] and policy DS16 [Regional Employment Sites] as development opportunities on greenfield sites on the edge of Coventry. The inclusion of the Site in the SWLP would represent a logical extension to the existing allocations identified on the edge of Coventry. Figure 2-3 Previous Green Belt Release Allocations in the South of Coventry area Kenilworth/south of Coventry area 2.20 An important context for the site, is the work being undertaken by Warwick District Council, alongside partners Warwickshire County Council, Coventry City Council and the University of Warwick, looking at a master planning framework for land to the north of Kenilworth/south of Coventry area. The site its firmly in the centre of this study area and is well placed to o utilise the supporting infrastructure already in place. Considering Coventry Gateway West in the future context, the Site would benefit from access to the infrastructure that will now be delivered at the Southern Gateway (application reference W/21/1370) and possibly at the Airport and be able to provide further employment opportunities for new residents or an expansion of the commercial activities on the site through a new commercial business park. Figure 2-4 Map showing previous allocations, permissions, with first round Call for Sites submissions and HS2 safeguarded route 2.21 When presenting the current adopted plan allocations (housing and employment) on a map with the new Call for Sites submissions (from May 2021) and the defensible boundary that will be formed by HS2, it becomes visually clear that a growth pattern (i.e., a southern arc) can be formed around Coventry. The Site at Coventry Gateway West (outlined in red above) is strategically placed between existing and new employment opportunities and existing housing allocations, creating a clear opportunity for sustainable growth including travel options for potential new residents or new places of work for existing residents. 2.22 In summary, inclusion of the Site in the SWLP would represent a logical extension to the existing allocations identified on the edge of Coventry, when viewed in the existing and future context of largescale neighbouring development.

Intensification options Q-S2. Please select the [Intensification] option most appropriate for South Warwickshire 3.14 The housing requirement identified across the Coventry and Warwickshire HMA shows a need for 4,906dpa. The SWLP will therefore need to set out a potential total supply for the plan period. Not achieving this would mean that the approach towards supply and delivery of housing land is not justified, effective or consistent with national policy. The Council’s general approach to estimating dwelling capacity to date has been to assume a density of 35dph for greenfield sites and 50dph for urban brownfield sites. The net developable area for edge of village sites and most brownfield sites is assumed as 66% of the gross site area and for strategic greenfield sites this previously has fallen to 50% to reflect the additional infrastructure and strategic landscaping which is likely needed. RPS consider that the Council should take a cautious approach to estimating site capacity through intensification, to ensure they are realistic and justified. 3.15 We therefore consider Option S2c ‘Not having a policy which encourages intensification’, to be the most appropriate option for South Warwickshire given the rural nature of the district and recognising that the estimates are not the upper limits on the number of dwellings that could come forward on sites. Q-S3.2. Option [brownfield development] which is most appropriate for South Warwickshire 3.17 RPS consider that broadly the proposed housing growth option most appropriate for South Warwickshire is Option S3.2c. We do not agree with the way that this option sets out greenfield sites (particularly in respect of the Green Belt) as a measure of last resort only to be considered if all alternative options are exhausted. Neither the NPPF nor planning guidance defines Green Belt as an absolute constraint on development that should automatically preclude Green Belt sites from the assessment of suitability for development and does not specifically identify Green Belt as a constraint (ID: 3-018). Notably, the PPG states that: 3.18 “Identified sites, which have particular constraints (such as Green Belt), need to be included in the assessment for the sake of comprehensiveness but these constraints need to be set out clearly, including where they severely restrict development. An important part of the desktop review, however, is to identify sites and their constraints, rather than simply to rule out sites outright which are known to have constraints.” (ID: 3-010) 3.19 The guidance is clear that Green Belt development sites should be considered alongside other options rather than separately or as a later phase of the process. Notwithstanding the other concerns regarding a brownfield approach, such as concerns relating to loss of businesses and our concerns that brownfield sites may struggle to provide green infrastructure due to site constraints, and blanket approaches can often impede development. 3.20 Equally, in the context of changes to national planning policy, the Department for Levelling Up, Housing and Communities (‘DLUHC’) is consulting on proposed changes to Green Belt reviews, whereby “Green Belt boundaries are not required to be reviewed and altered”. However new paragraph 142 of the draft Framework text goes onto state, “strategic policies should establish the need for any changes to Green Belt boundaries…”. RPS therefore contend it is important for SWLP authorities to maintain a Green Belt review on the southern side of Coventry (even in the event the draft changes put forward by Government are agreed), as this is an area of strategic important for the sub-regional economy and cross-boundary housing needs. Growth of existing settlements and the growth strategy Q-S4.1. Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.21 Yes, we agree that a distribution strategy for new development within South Warwickshire is important to consider the potential for growth around the edges of the existing settlements. 3.22 We accept that existing towns and villages provide varying levels of facilities and services to meet the needs of the people who live or work in and around them. Some of the larger settlements act as a hub for surrounding small villages. It is important to recognise the benefits of 20-minute neighbourhood principles whereby people are able to meet their regular day-to-day needs within reasonable walking distances. This concept follows the objective of sustainable development and aligns with the overarching principles of this Local Plan review. 3.23 RPS take issue with the exclusion of settlements on the edge of the district boundaries where the benefits of adjacency to a larger urban area is of benefit to the locality (i.e., edge of Coventry). The I&O consultation document states that to help inform consideration as to whether there is potential for new development - to help deliver the advantages of a 20-minute neighbourhood - a settlement analysis evidence base has been developed to help identify the opportunities and constraints to growth in and around the edges of the following settlements and locations across South Warwickshire. Yet, we contend some settlements should be subject to connectivity, accessibility and density analysis, should include settlements surrounded by Green Belt – such as south of Coventry and in particular Coventry Gateway West site. This will help determine their favourability and sustainability credentials and whether they would fall within a growth option. Development distribution strategy Q-S10. Development distribution strategy for South Warwickshire 3.29 RPS advocate for a mix of approaches which is consistent with the desire for a 'flexible and responsive' spatial development strategy as highlighted in the SWLP, which would better enable the full growth needs of SW area to be achieved as intended. 3.30 In addition, in relation to the housing distribution strategy, RPS would recommend that key consideration in identifying suitable locations to address these neighbouring shortfalls should be to prioritise locations that are accessible and in close proximity to where the unmet need arises, thus reducing travel distances as well as offering the potential for linked service provision to meet the wider needs of the new communities. In strategic terms, this means that the re-distribution of any unmet housing need should be related to settlements on a duty to cooperate basis (whether this is from the West Midland conurbation, Coventry and / or Redditch), and which would clearly lead to an increase in the overall level of growth to be accommodated within the SWLP and the need for additional land to accommodate that growth. 3.31 RPS further recommends that key consideration is given to identifying suitable locations for employment opportunities also, to address the strategic employment issues that are crucial to accommodating suitable level of growth for the sub-regional economy. This is reflective of the ‘flexible and responsive’ strategy RPS considers is necessary.