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

Why is there no consultation question for issue S6 - A review of greenBelt Boundaries.? There is much to consider for the population's health, welfare, economy and other aspects about why greenbelt land should be protected and why North Leamington Greenbelt should be maintained, yet this section is presented as a closed case. This is unacceptable.

We agree with the consideration of development of areas within existing green belt, to rebalance the distribution throughout areas of South Warwickshire.

The absolute focus should be on Spatial Growth and the approach set out in this regard, with a focus on existing settlements with railway stations, good access and deliverable/viable economic growth potential (eg, Henley-in-Arden) is the correct one. We strongly support the spatial development strategy which includes Henley-in-Arden within each of the five spatial growth options due to its location and ability to deliver significant employment and population growth. In respect of a "threshold" approach and a focus on development within settlement boundaries, care needs to be taken. In general terms, such an approach has resulted in very poor planning outcomes over recent decades. We have seen town cramming reduce the liveability of places. Simply building more densely to avoid building outside an arbitrary settlement boundary is not good planning - it is a binary "brownfield good, greenfield bad" approach that has resulted in very poor land use planning outcomes. Henley-in-Arden has suffered from the impacts of "ad hoc" planning in recent years. With piecemeal, poorly-planned in-fill development that contributes nothing to the vitality of the town or necessary new infrastructure. There is an urgent need to plan for beautiful development and to implement good planning that provides for re-investment into places. This requires planners to plan - to identify appropriate locations for new development. Accepting the need for development enables all attention to then be focused on building beautifully - the SWLP brings the opportunity to revitalise South Warwickshire's key settlements by integrating them with sustainable growth. Forward Group and Alderley Holding’s Trust has set out a vision for its landholdings that would meet not only Henley-in-Arden’s but Stratford’s economic and social needs for the next decade and beyond. Done in the right way, this will result in direct, ongoing re-investment into communities, biodiversity, heritage, recreation, employment, active movement and so on. In this regard, the emerging SWLP has identified an appropriate Spatial Growth-focused approach that we fully support.

The South Warwickshire Local Plan Process should fully examine all other options, including new settlement options outside the Green Belt, before starting a study to review Green Belt boundaries in South Warwickshire. An area should maintain its Green Belt status if it meets any one of the 5 purposes of Green Belt, as defined in the National Planning Policy Framework.

Focus should be on better use of already developed land rather than building more greenbelt developments. It is clear that building on green field sites is a cheaper options for developers and easier from a local planning point of view but there are significant areas of brownfield land which should be developed to provide more affordable houses within the areas where people can work. This will ultimately benefit the local area by providing more affordable houses without the need to deliver extra infrastructure (rail roads and busses) and by not destroying the countryside with more developments that can only realistically be accessed by car drivers. Development of our towns should be the priority rather than joining up our villages with development, this is the only option that delivers a sustainable future.

The Green Belt around the North of Leamington is a highly valued open space. Local residents tell us that it is very valuable to them for both their physical and mental health. It is visually of a very high quality and has a number of easily accessible public footpaths across the fields. These footpaths were heavily used during lockdown, and the gratitude that residents felt to the local farmer for his understanding was evidenced by the thousands of pounds raised for the charity of his choice. The agricultural land provides rural employment and the mixed arable, grazing and wildlife refuge all helps to maintain the wonderful ambience of the rural village of Old Milverton only a short distance from Leamington Spa, but with a totally rural feel. Development within the Green Belt to the north of Leamington Spa would substantially reduce the land that separates Kenilworth from Leamington Spa. This is even more the case since the current Local Plan which in reviewing the Green Belt removed land to the south of Kenilworth and north of the A46 from the Green Belt. The joint Green Belt study in 2015 highlighted the contribution to preventing the merger of Leamington Spa, Kenilworth and Coventry that this part of the Green Belt makes by stopping urban sprawl, protecting the countryside and preserving the special character of these differing but very special historic towns. The officers have done considerable work on the Issues and Options consultation of the South Warwickshire Local Plan, but sadly the process is flawed because all five spatial growth options involve some development in the Green Belt. It is even more unfortunate that all of them refer to the Green Belt to the North of Leamington as an area of ‘significant urban extension’. This all appears to ignore the legitimate function served by the Green Belt, and is contrary to very recent Government announcements, the 2015 green belt review and the detailed 2017 response by the Planning Inspector.

1 Green Belt was set up to protect the countryside. The development of South Warwickshire does not protect the countryside . 2 Another purpose for the Green Belt is to conserve natural habitats for wildlife and make boundaries . Surely there is more need now to preserve these areas especially with the development in South Kenilworth and the proposed changes to North Leamington the wildlife corridor becomes ever diminished .

I would hope that each individual location will be treated on its' merits. There are some sites which, although the landowner would wish to see development, remain unsuitable. I hope that local needs will be taken unto account when planning applications are submitted.

The South Warwickshire Local Plan team should examine all other areas of land before resorting to using Greenbelt land for development. It is all to easy to look at this land as the easy route, especially when you have land owners who are prepared to profit from the development. The Greenbelt policy was put in place to protect our green spaces from our generation. We are the custodians of this country and should protect it for future generations. The Greenbelt land in South Warwickshire is used by thousands each week for health and well-being, including for those with mental health issues where getting outdoors into open space, close to their home is imperative to their existence.

I wish to object to the inclusion of the “Weston under Wetherley South” site for mixed development as part of the new SWLP. My reasons for this are as follows: Earmarking this site for development would completely ruin the character of the area, which is of a small village separated by greenbelt farming land from another, even smaller village. It would also join the two villages, contrary to the NPPF, and result in housing to accommodate more residents than are currently in Weston and Hunningham combined. Further, your sustainability assessment provides no analysis of this site/village as a possible location for a new/expanded settlement on any level and to any scale. It cannot therefore possibly be considered for inclusion as a site for development within the local plan. Government guidance states green belt should only be used for development where there are good reasons- specifically very special circumstances in which planning ought to proceed, and “exceptional circumstances” to alter green belt boundaries (NPPF 140). There are no such reasons in this case. It is simply not necessary to release the green belt land for development and, importantly, there is nothing to show the Council could meet the requirements to offset the loss of green belt land that would result from including the site for development as part of the new local plan. Further, this approach would require “exceptional circumstances” to establish new green belt land to compensate for any loss as set out at NPPF 139 and there is not enough evidence to show the Council has “examined fully all other reasonable options for meetings its identified need for development” (NPPF 141)- rather it is trying to use the consultation responses of fewer than 600 people in an area with hundreds of thousands of residents to justify the approach, which is not at all in keeping with the NPPF. None of the exceptions set out at NPPF 149 would apply to new development on this scale in WuW The land is important to maintain openness and development would severely detract from this and completely change the rural nature of the villages, contrary to NPPF 144. It is also a flood plain, development of which would increase flooding issues at/around the Red Lion pub in Hunningham and would inhibit the ability of the land to absorb surface water, making flooding worse. There is a large amount of land outside the greenbelt, largely within Stratford District Council’s area to the South of Leamington which performs as well if not better than any of the sites north of leamington (in the green belt) in the Council’s sustainability assessment. Any development at the site would also not be sustainable: Public transport links are virtually non-existent and there is no access to railway stations or any major bus network. This would mean that any use of the site would require all users (whether residential or otherwise) to travel to it by private transport, which is against the aims of the NPPF 142 (“Where it has been concluded that it necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.”- neither applies to WuW. There are no accessible pedestrian links between the site and any towns/public transport hubs. Access is only along the Rugby Road, which has no pavement, or through fields and via diversions to account for HS2. The location marked as possible access for development (and indeed any point that could act as access) is on a narrow country lane with no real prospect of widening the road between Weston and Cubbington to the West, Hunningham to the South, Wappenbury to the East or along Waverley Wood to the North. We have recently experienced a number of road closures between Weston and Cubbington and this has resulted in diversions along Weston Lane by Waverley Wood and the road is already unable to cope with this level of traffic- at points it is not wide enough for two vehicles and it involves an unsighted bend which is dangerous for road users. The site is also not close to any major road network and, as above, local road infrastructure would not be able to cope with the additional movements resulting from any development at the site, let alone something of this scale. Local schools, doctor’s surgeries, shops, etc could not cope with any additional demand on this scale We have already suffered a significant loss of woodland/greenbelt as a result of the HS2 works in the area and further development would impact on habitat for protected species including bats, badgers and possibly other species such as newts. The land contains a significant amount of protected hedgerow which would be lost and would also impact on birds. Part of the site is also a flood plain- flood maps show parts of the site are at risk of surface water and river flooding and development of the open fields would likely further increase this There are also wider implications from allocating the site for development- the land is currently used for farming and development would impact on food security and the country’s ability to provide for itself. More generally, the Council should not be looking to support development in the green belt to the scale proposed for any of the options. As above there are no very special circumstances to justify this level of development in the green belt when there are perfectly suitable options available outside it. If a new settlement of 6,000 dwellings south of Leamington spa, outside the green belt, can support a new station along the existing rail line this would also open up possibilities for other smaller settlements with decent public transport links around the same location, whereas at present possible areas for development are disproportionately focused on the greenbelt north of Leamington spa despite this only accounting for less than 1/3rd of the total area of the combined districts. Land to the South-east of Leamington meets the requirements for rail access (even if this would require a new station) and there are such a large number of sites proposed in non-green belt land to the South and East of Leamington that there surely cannot be the required justification to promote new settlements in the green belt. While the Council quotes figures of more than 50% in favour of exploring development options within the green belt, the number of consultation responses means that this amounts to fewer than 300 people out of a combined population of hundreds of thousands. A large proportion of these individuals are also likely to be developers or those with some interest in developing the land. The approach taken by the Council with all of the options tabled is not proportionate and the number of sites and scale of the proposed developments may well exceed what consultees had in mind when responding to the questions, as there was no differentiation between 1 small settlement of 50 houses and 20 large settlements of 6,000 dwellings or more, for example.

Q-S4.1: Yes, growth of existing settlements should be the main option within the overall growth strategy. This ensures making best use of existing infrastructure and sustainable patterns of development. Please see full response to this at Q-S7.2. Q-S9: We support Option S9b. It is clearly essential that the Part 1 Plan should include a fresh review of all settlement boundaries.

We would like to make the following additional points as there was not an option to expand on answers in the relevant sections: (S1) Without the Local Nature Recovery Strategy there is no guarantee that any green or blue corridors identified by SWLP will have a beneficial impact on nature. For this reason we suggest that neither options S1a or S1b are appropriate. It would be better to identify corridors after a strategy has been produced. (S2) Certain types of intensification in town centres should be supported for example the conversion of unused retail property, including upper floors, to provide housing. (S6) The statistical underpinning of this section is flawed. The 54% figure cited in favour of Green Belt development is, at best, misleading. This is not a representative figure because the respondents to the first consultation were not a representative sample. Analysis of respondents on this issue shows that 35% were developers and 10% were landowners or businesses, suggesting that only a small proportion of other respondents were in favour (see Consultation Statement January 2022, p275). This skew towards groups with a vested interest means that this statistic should not be used as justification for pursuing this strategy. We are concerned that improper analysis and misleading conclusions may be taken forward and used to provide evidence of exceptional circumstances for developing the Green Belt. Green Belt boundary review does not need to happen (from a policy perspective) and should not happen (from an environmental safeguarding and wellbeing perspective). If it were to happen, it should be part of a strategic West Midlands Review rather than a piecemeal exercise (West Midlands Land Commission, 2017). In view of all of this we argue that the process should be halted and the parameters of the Local Plan shifted so that Green Belt development is not assumed. The non-Green Belt growth options that were explored in Part 1 of the spatial growth workshops should be prioritised and communicated and the wishes of local residents should be listened to.

Trying to amend or create new boundaries of settlement in Part 1 will means that non-strategic allocations will not be included and then the boundaries will not accurately reflect smaller allocations that may come forward. At the moment there are inconsistencies in the way the authorities approach boundaries and development, and this would remain until Part 2 of the SWLP is completed. However, there is no reason why there cannot be a boundary review policy within Part 1 which sets out the aspirations to allow existing settlement boundaries to be reviewed and amended subject to any non-strategic allocations which may come forward or are a part of Plan 2. A review policy like the one to review the housing numbers in the existing Warwick Local Plan after 5 years of its adoption. We would like to point out however that currently the settlement boundaries for villages in both Warwick and Stratford, are extremely tightly drawn, and in practical terms leaves very little opportunity for infill development to take place. A site like Bush Heath Lane should for example help to re-examine boundaries for existing settlements, and amendments made to accommodate this small-scale growth, as early as possible to be able to make it easier for the SWLP to identify land for housing as well as the numbers.

The South Warwickshire Local plan process should fully examine all other options, particularly including new settlement options outside of the Green Belt, before starting a study to review Green Belt boundaries in South Warwickshire. The towns of South Warwickshire have an unique character which stems from their effective integration into the surrounding countryside. The Green Belt is a critical element in creating this character, and exists for precisely this purpose. There are also significant brownfield areas across the West Midlands where development should be encouraged, and although I'm a city dweller I value our countryside and further encroachment should be discouraged. These are all purposes of the Green Belt as set out in this consultation, and it is clear that areas should maintain their Green belt status is any one of the purposes are met, let alone three or four.

1. I hope that the SWLP will be regularly reviewed. Current government policy is based on current or dated statistics, which may change over time, such that it may be found that less development is needed in South Warwickshire and in the country as a whole. This could be due to the average life expectancy reducing due to obesity and a reduction in the number couples having families - and continuing to have smaller families. Any development must be carefully considered and LA's must not be simply led by developers, who have no real regard for the legacy they leave at any development. Furthermore Green Belt should be retained wherever possible and brownfield sites should be used wherever possible. Finally every development, large or small should be attractive and bring benefits to the whole community.

No account of the inadequacy of existing infrastructure to support the dwellings that have already been built. Many of these received planning assent before the Core Strategy was approved or even developed, therefore were not subject to any spatial considerations. Existing infrastructure shortfall needs to be addressed.

The Harbury Society does not have the resources to reply to the consultation in detail, item by item. We have therefore largely confined our comments to our primary focus of Harbury village and thereby to medium and village communities in general. It is therefore hoped that the following comments will be helpful and taken into account. Regarding housing and other buildings we note that recent developments tend to be high density with small plots which house holders subsequently pave for parking and outdoor seating areas, leaving little space for planting and biodiverse habitats have no gain and resulting in reduced flood mitigation. In connection with any future housing developments we consider the gains in biodiversity are vital to the well-being of our surrounding countryside and that the “Net Gain” provided by any development should be more than 10% with a stated ambition of 20%. We therefore agree with the statement in the climate change section of the plan that “ land is generally of good quality and is an asset that should be afforded appropriate levels of protection from housing growth and large scale development that would harm land productivity”. We believe that the use of any agricultural land that is planned for solar panels should be reviewed under this statement. We further believe that solar panel farms are an unproductive way of producing energy in the UK due to the intermittent and unreliable nature of sunshine and to take away large hectares of land from food production is frankly not sensible. The fact that the solar farms also uglify the landscape for little productive purpose for 30 years will be a legacy which we believe will be viewed hugely negatively by future generations. The likelihood of the land returning to agricultural land would seem low. We believe that all commercial/industrial developments should have solar panels fitted on construction. Also incentives should be offered to fit solar panels to new house builds. Our local environment and its assets including access to local footpaths and cycle ways are very valuable to the village and similar communities throughout Warwickshire. An example of this is that there are footpaths that connect Southam to Harbury and then a cycleway/footpath that connects Harbury to Whitnash and hence Leamington Spa and Warwick. It would not be a too challenging or costly task (and appropriate use of CILL funding) to upgrade these to make these journeys both low carbon and convenient. Resulting in a through cycle/footpath route from Southam to Leamington and Warwick. Certainly, the cyclists using Harbury Lane are in continuous danger from road traffic on a narrow lane. Existing green areas around the communities including pastures, trees and woodland should be protected from development and maintained or enhanced to encourage diversity of species. Green space within the communities should be similarly conserved. Where any developments around village communities are desired they should be confined to areas of land of limited size which is visually acceptable in the landscape which integrates and mitigates any major changes to the feel and culture of any village which will have been established over 100’s of years. They should have low impact on natural habitats around them and mitigation to be provided with open space and green corridors within them. This surely is a key part of the stated aim to provide a well-designed and beautiful South Warwickshire. The truly ugly nature of the housing development on Europa Way in Leamington makes us question the implementation of this ambition. It is evident that there is an expectation that South Warwickshire are planning for migration into the area from other authorities such as Coventry and the Black country. Our recommendation is that high rise living in the towns and cities particularly in Coventry and Birmingham is an inevitable progression for cities and large towns. This should be considered and included in the Plan and used as pushback to the other authorities. The plan appears to also accept that this will inevitably require more agricultural land and changes to the Green Belt. We accept that the latter must be redefined so as not to put excessive pressure on the other parts of the Warwickshire landscape. However, we would like to make the key point that the implication of spreading out the developments is to create a conurbation including Warwick, Leamington spa, Whitnash, Radford Semele, Bishops Tachbrook, Southam and other fringe villages would be a failure of the planning system. All 5 solutions seem to indicate that this is a very likely outcome. Even in the worst case scenario a policy that stops any spread of urban development beyond the Tachbrook Road should be enforced and also be bounded by Harbury Lane and the Fosse Way to protect the rural nature of South Warwickshire encompassing village environments, natural habitats and productive farmland. In our view the potential Deppers Bridge proposals to establish a large housing development conflict with all the above sentiments.

Concentrating on the strategic infrastructure with the growth strategy is more appropriate than trying to apply it across all locations. Strategic infrastructure such as transport and healthcare are matters which are governed and managed by Warwickshire County Council. The growth strategy will have to involve large scale strategic developments which will then provide the physical and social infrastructure that is required to meet the demands of new settlements. The option to set out infrastructure requirements for all scales, types and location of development in Part 1 and then apply this to all types of development, would mean that potential uses would need to be modelled to understand what potential impact they would have and what infrastructure would be needed. It will be difficult to take into account windfall sites for example as it is unknown where these would be and how much of the overall housing numbers they are going to be accounted for. Trying to amend or create new boundaries of settlement in Part 1 will means that non-strategic allocations will not be included and then the boundaries will not accurately reflect smaller allocations that may come forward. At the moment there are inconsistencies in the way the authorities approach boundaries and development, and this would remain until Part 2 of the SWLP is completed. However, there is no reason why there cannot be a boundary review policy within Part 1 which sets out the aspirations to allow existing settlement boundaries to be reviewed and amended subject to any non-strategic allocations which may come forward or are a part of Plan 2. A review policy like the one to review the housing numbers in the existing Warwick Local Plan after 5 years of its adoption. We would like to point out however that currently the settlement boundaries for villages in both Warwick and Stratford, are extremely tightly drawn, and in practical terms leaves very little opportunity for infill development to take place.

The Canal & River Trust is the charity which looks after and brings to life 2000 miles of canals & rivers. Our waterways contribute to the health and wellbeing of local communities and economies, creating attractive and connected places to live, work, volunteer and spend leisure time. These historic, natural and cultural assets form part of the strategic and local green-blue infrastructure network, linking urban and rural communities as well as habitats. By caring for our waterways and promoting their use we believe we can improve the wellbeing of our nation. The Trust is a statutory consultee in the Development Management process. Within South Warwickshire we operate of 80km of canals, comprising parts of the North Stratford, South Stratford, Oxford and Grand Union Canals. The Trust does not wish to comment on the merits of the different options under consideration, but we do consider that it is important for any options selected to have regard to the canal network within the Plan area. The canal network is a multi-functional resource and is an important heritage asset, leisure, recreational and tourism resource, which can offer significant benefits to the health and well-being of local communities through offering a free-to-use active travel option for walking and cycling as well as playing an important role as a wildlife habitat supporting a wide range of biodiversity and providing a link between other green spaces and habitats. New development should seek to strengthen the role of canal corridors as part of the strategic green/blue infrastructure network, and particularly their value in providing a connection between other areas of green space. The canal network should therefore be identified within the Plan and taken into account when determining which growth strategy option to select.

My understanding is that for an area to maintain its Green Belt status, it need only meet one of the five purposes of the Green Belt as laid out in the NPPF, not all five as erroneously proposed in this consultation.

Before this can be addressed, you would need to address my earlier comments on the overall issues around growth strategy (eg why growth not productivity).

It is not clear that the South Warwickshire Local Plan Process has fully examined all other options, particularly infill and brownfield sites, and including new settlement options outside of the Green Belt. This should be done before any study to review Green Belt boundaries in South Warwickshire.

The site in question wood take a large part of green belt land already eroded by HS2. Since the building of the Burrow Hill estate at the top of Red Lane the water pressure and sewage system is severely overstretched and could not take another housing estate. Without the relevant support infrastructure of roads, schools, doctors etc. the current facilities would not cope. We would loose valuable sheep farming and wildlife environment already severely affected by HS2. The fields in question are prone to flooding and would need drainage diverting flooding from existing and proposed houses.

Should consider measures to prevent existing towns / settlements from coalescing and preserve identity of individual places.

Why is there no consultation question for Issue S6 - A review of Green Belt Boundaries. This is not in line with current Government policy which says that Green Belt should be protected and does not have to be released to meet housing demand.

The HS2 route should not be considered a railway corridor as it does not serves South Warwickshire; land in this corridor should not be seen area of potential spatial growth

I think it's important that the Local Plan process should fully examine all other options, for example new settlement options outside the green belt, before beginning a study to review green belt boundaries.

To enable greater scope for housing development, the plan should allow for developments to come forward where they are adjacent to existing settlements. A restriction of 10 dwellings of fewer might not go far enough to deliver the aspirations of the plan area, and this should be an amount proportionate to each settlement, on a case-by-case basis, factoring in the sustainability credentials of a settlement.

It is difficult to pose a size limit for individual sites, given that these will be attached to a wide range of settlements, varying themselves in size. It would be more appropriate to propose a proportionate amount of growth increase for each settlement, or classification of settlement, so that growth is not unduly restricted where a settlement is capable of accommodating higher levels due to good levels of service provision and connectivity.

Long Marston is a perfect location for a new settlement. The village, airfield and Meon Vale need to be linked together to provide sustainable infrastructure and facilities. Current houses are being sold quickly, identifying a need for more residential housing. Facilities that would benefit include houses, retail, industrial, education, leisure and medical facilities. The ralline need to be reinstated or an alternative such a land train could be utilised to ferry passenger to Stratford station or to Honeybourne station for city links from Long Marston. This would also reduce road traffic as locals could use this facility for their day to day travel, this would reduce pollution, helping this settlement to be net zero. In the Core Strategy Long Marston Garden Village has plans for a Long Marston Park and Ride, with a rail station all within Cala homes master Plan - this cannot be overlooked and needs to be carried forward into the forthcoming plan. Development around the A3400 Lapworth/Hockley Heath is ideal. There is the rail station at Lapworth, there is Junction 16 of the M40 and full accessibility to the NEC' s business park and Blyth Valley Business Park and the HS2 line. These locations support jobs. The A3400 is accessible taking you into Stratford upon Avon and Solihull. Solihull have an over spill for Birmingham and themselves, with the proximity of Lapworth - these development sites need to be a priority as it would meet the know needs of Birmingham and Solihull's overspill requirements without infrastructure implications or additional concern for jobs. Development needs to happen swiftly in South Warwickshire, with clearly planned out development strategy which will benefit future generations. Development is needed round the rail corridors, but we cannot remove the need for small scale developments just out side these settlements, ensuring villages are part of this expansion. Village boarders need to be reviewed because at present they are extremely restrictive and controlled by local residents who are resistant to change. An independent body, which would be unbiased in it approach and not restricted by NIMBYS needs to be established to review and amended these boundaries . Development cannot be piecemeal it need to have structure and to benefit the whole community, this is once in a generation opportunity and time to show forward thinking and planning for the 21st Century.