Issue and Options 2023

I write on behalf of our client Thwaites Ltd, in response to the South Warwickshire Issues and Options Consultation in the interest of ‘Land to the south of Thwaites Ltd, Cubbington’ (‘the site’) and it being suitable for removal from the Green Belt as part of the South Warwickshire Local Plan Review. The Issues and Options Consultation and Call for Sites for the South Warwickshire Local Plan, is running for a period of 8 weeks between Monday 9 January and Monday 6 March 2023. The purpose of this consultation is to welcome any interested parties, Parishes, individuals, landowners and developers to inform the Local Planning Authority (LPA) of any sites within the district that they consider suitable to accommodate future housing and employment as part of the SHELAA. In this representation we discuss the suitability of the site for removal from the Green Belt to support the businesses needs as a significant employer during the Local Plan period, in accordance with the economic objectives of the Local Plan and the NPPF. It is emphasised that this representation regards the site only. It is noted from the South Warwickshire Local Plan website that a Green Belt review is not currently planned, which would lead us to assume that Green Belt release is not considered a strategic proposition. Site Location and Description The site is located adjacent to the existing Thwaites business, outside, but adjacent to the settlement boundary within the Green Belt, as shown on the map below. Thwaites Thwaites has existed for almost 80 years and now provides a significant number of jobs. The business requires specialist equipment, processes and facilities. It has and continues to invest significant capital at its existing site to achieve this and it would be very expensive to relocate to new premises. Thwaites business is for the manufacture of dumper trucks which are sold globally and has seen a significant increase in demand over the last few years. Since 2012, annual revenue has trebled to circa £95M, this significant increase in demand has been attributed to the housing market in both the UK and continental Europe, HS2 in the UK, and infrastructure projects. It is envisioned that this increase in demand will continue over the coming years as the housing shortage continues to drive house building projects in the UK for which Thwaites distributors supply machines. Thwaites single site operation has not expanded geographically and continues to provide a significant number of jobs and requires more site space to satisfy storage and logistics needs and there we would like to apply for the removal of the area of land as indicated in the attached plan. Relevant Planning Policy The current development plan for the site comprises the Warwick Local Plan (2011-2029) adopted in September 2017. Policy DS4 sets out the spatial strategy of growth in the Warwick District. The policy aims to focus growth within and adjacent to built-up areas, with the majority of growth being focused on the main urban areas of Warwick, Leamington, Whitnash and Kenilworth, with some growth being directed to the growth villages such as Cubbington. Figure 1: Warwick District Council Green Belt Plan. The site is edged in red. Black is the defined settlement boundary. This spatial strategy also takes national Green Belt policy into account. It outlines that sites in the Green Belt will be limited to those locations where exceptional circumstances can be justified. The following will be taken into account in considering exceptional circumstances: i. the availability of alternative suitable sites outside the Green Belt; ii. the potential of the site to meet specific housing or employment needs that cannot be met elsewhere; iii. the potential of the site to support regeneration within deprived areas; and iv. the potential of the site to provide support to facilities and services in rural areas. Policy DS19 of the adopted Local Plan confirms the Council will apply national guidance within the Green Belt. The fundamental aim of the Green Belt policy is to prevent urban sprawl and keep land permanently open. National Planning Policy Framework Since the submission, there has been a revised National Planning Policy Framework (‘the Framework) that was issued in July 2021. The most relevant policies are enlisted below: Chapter 13 regards the protection of Green Belt Land. Specifically, Paragraph 137 states that “the Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence”. Paragraph 138 sets out that Green Belt serves five purposes: • to check the unrestricted sprawl of large built-up areas; • to prevent neighbouring towns from merging into one another; • to assist in safeguarding the countryside from encroachment; • to preserve the setting and special character of historic towns; and • to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Paragraph 140 states “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans”. Paragraph 141 states that once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use. Paragraph 147 defines ‘inappropriate development’ as development that is ‘harmful to the Green Belt and should not be approved except in very special circumstances. Paragraph 149 sets that that “a local planning authority should regard the construction of new buildings as inappropriate in the Green Belt”. Exceptions to this are: 1. buildings for agriculture and forestry; 2. the provision of appropriate facilities (in connection with the existing use of land or a change of use) for outdoor sport, outdoor recreation, cemeteries and burial grounds and allotments; as long as the facilities preserve the openness of the Green Belt and do not conflict with the purposes of including land within it; 3. the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building; 4. the replacement of a building provided the new building is in the same use and not materially larger than the one it replaces; 5. limited infilling in villages; 6. limited affordable housing for local community needs under policies set out in the development plan (including policies for rural exception sites); and 7. limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings), which would: - not have a greater impact on the openness of the Green Belt than the existing development; or - not cause substantial harm to the openness of the Green Belt, where the development would re-use previously developed land and contribute to meeting an identified affordable housing need within the area of the local planning authority. Issues and Option Consultation Questions Policy EC1 relates to ‘directing new employment development’. Cubbington is identified as a Growth Village and the site is situated within the Growth Village Envelope as defined on the policy map. Policy EC1 relates to directing new employment development and identifies that in rural areas. Having reviewed the consultation document we wish to respond to the following questions as part of this representation. • Issue E1: Growing the South Warwickshire economy • Issue E8: Existing employment sites • Issue 11: Any other economic issues

Nothing chosen

In the HEDNA for Warwick, it is acknowledged that ‘Coventry and Warwickshire is a £26 billion economy, accounting for 19% of West Midlands GVA. Immediately prior to the Covid-19 pandemic, growth in GVA was slightly out-performing regional and national trends reflecting stronger performance of the sub-regional economy post 2013. Total employment in 2019 across Coventry and Warwickshire is estimated at 526,900 jobs’. Therefore, it is considered that Thwaites is a significant contributor to this figure given that Thwaites annual revenue since 2012 has trebled to circa £95M, this significant increase in demand has been attributed to the housing market in both the UK and continental Europe, HS2 in the UK, and infrastructure projects. Overall, we consider in response to question E1.1 that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire. However, emphasis that to sustain the growth of the established Thwaites employment site removal of the land from the Green Belt is required.

Issue E8: Existing employment sites The Thwaites site although not an allocated employment site it is well established and the Local Plan Policy EC1 supports new employment development in rural areas in certain circumstances, this includes for sustainable development within Growth Villages. Therefore, other than to say that existing businesses should be fully supported (as pe the NPPF) we have no further comment in relation to the carry over of existing employment sites in relation to question E8.1. Issue 11: Any other economic issues It is recommended that the land shown in the accompanying location plan be removed from the Green Belt. It is required to enable Thwaites, an established business (who has been operating for almost 80 years), to expand in a sustainable way and continue to provide employment for the existing community throughout the plan period.

Green Belt Considerations Joint Green Belt Study (JGBS) The most recent review of the Green Belt was undertaken in 2015 as part of the evidence base supporting the Warwick District Local Plan. This study assessed the Green Belt in Warwick District council against the five purposes of Green Belts, as set out in the National Planning Policy Framework (NPPF). The site is located in Broad area 3, which lies between Royal Leamington Spa to the south, Kenilworth to the north west, Coventry to the north and Rugby to the north east. The area contains the Registered Park and Garden at Stoneleigh Abbey, several Scheduled Monuments and Grade I listed buildings and substantial pockets of ancient woodland, including Ryton Wood SSSI. The JGBS found that the area made a considerable contribution to all the purposes of Green Belt for the reasons set out below: • Checking the sprawl of Royal Leamington Spa, Kenilworth and Coventry. • Preventing the merging of neighbouring towns in the long term, particularly Royal Leamington Spa and Kenilworth and Kenilworth and Coventry. • Safeguarding the countryside, including a number of large woodlands, such as Ryton Wood. • Preserving the setting and special character of the historic towns of Royal Leamington Spa, Kenilworth and Coventry. The historic core of Kenilworth is located on the opposite side of the town, meaning that the broad area makes little contribution to the setting and special character of Kenilworth. However, panoramic views in to the historic cores of Royal Leamington Spa and Warwick to the south are common in the southern half of the broad area and there are some distant views of the historic core of Coventry close to the northern edge of the broad area. • Assisting urban regeneration by encouraging the recycling of derelict and other urban land across the West Midlands. It is our considered view that nothing has changed to alter the conclusions of the JGBS in 2015. However, we recommend that the site be removed from the Green Belt allocation in accordance with Paragraph 138 of the NPPF. Protecting Green Belt Land The Framework also states that before considering releasing land from the Green Belt, Councils will be required to demonstrate that exceptional circumstances exist to justify changing the Green Belt boundary. This will be accessed through the examination of strategic policies but should consider all other reasonable options for meeting identified needs. These include: • Making as much use as possible of suitable brownfield sites and underutilised land; • Optimising the density of developments; and • Discussions with neighbouring authorities to ascertain whether they could accommodate the identified need. We note that in selecting sites on the edge of urban areas, the adopted plan favoured non-Green Belt over Green Belt sites where possible. However, where there were no suitable non-Green Belt alternatives, sites were removed from the Green Belt to enable development to take place. Purposes of the Green Belt Vitally the suitability of the site’s removal from the Green Belt can be demonstrated through setting the site against paragraph 138 of the NPPF, which identifies the five purposes of Green Belt land. The site is set out against each of the 5 purposes as per paragraph 138: Purpose A - to check the unrestricted sprawl of large built-up areas; The location of the site is adjacent to the existing Thwaites site and by virtue adjacent to the existing defined settlement boundary. Removal of the site would not cause a significant adverse impact on the openness of the Green Belt nor would it result in a sprawl given that the boundary of the subject site does not extend beyond the boundary of Thwaites existing boundary. Purpose B - to prevent neighbouring towns from merging into one another; It was acknowledged in the Joint Green Belt Study 2015 that the Green Belt plays a crucial role in preventing the merging of neighbouring towns. We support this general motion although there will be instances where land in the Green Belt can be released without having a significant impact its objective to prevent towns from merging since the site doesn’t project beyond the boundary of the existing site to the north. Purpose C- to assist in safeguarding the countryside from encroachment; Paragraph 140 notes that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Therefore in the case of the subject site and on behalf of our client we ask that the land in question is removed from the Green Belt to support the business and allow its growth over the Plan period. Purpose D - to preserve the setting and special character of historic towns; and Releasing the site from the Green belt will not harm the setting and special character of historic villages and historic buildings, and, in turn, will not cause damage to their historic landscape. Purpose E - to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The site’s release from the Green Belt will not prevent or prejudice urban regeneration. Whilst we understand and appreciate the value of utilising derelict and other urban land rather than developing the Green Belt.

Summary Overall, it is recommended that the land shown in the accompanying location plan be removed from the Green Belt. It is required to enable Thwaites, an established business (who has been operating for almost 80 years), to expand in a sustainable way and continue to provide employment for the existing community throughout the plan period. Indeed, its removal from the Green Belt would not cause significant harm to the five purposes of including land in the Green Belt. Coupled with this expansion of the business is considered to be in accordance with policy EC1 which supports sustainable growth and expansion of existing rural businesses and enterprise. We note from the South Warwickshire Local Plan website that a Green-Belt review is not currently planned as part of the evidence for the Local Plan. However, we would hope on the basis of the contents of this representation the site will be considered for removal from the Green Belt.