CPRE Warwickshire Representations On South Warwickshire Plan (REG 19)

September 2026

 

Full Text of CPRE Warwickshire representations to the SWLP

 

 

Publication (Regulation 19)

SWLP Section 2  Development Strategy: South Warwickshire 2050

 

Strategic objectives:

 

Strategic Objective 1: Providing infrastructure in the right place at the right time – Ensuring development is supported by the timely delivery of infrastructure needed to support the growth in new homes and jobs”. Placing this objective first shows the SWLP as being about further development of South Warwickshire when the level of urbanisation reached is already risking harm to the existing pattern of towns, villages and open countryside.

 

Strategic Objective 2: Delivering homes that meet the needs of all our communities – Allowing growth in new homes that meet the diverse needs of our residents” would be sound if the Plan were based on existing population and natural change, ‘Meeting the needs of all our existing communities’ is supported, but the Plan is based on net in-migration of up to 126,000 people over 25 years who do not live in the area now and will not do so unless new housing is built for this increase in population. The ‘growth in new homes’ is not necessary for existing communities; natural population change (births and deaths) is projected to be low, with a fall in Stratford District and a small increase in Warwick District.

 

Strategic Objective 3: Developing opportunities for jobs and growing the economy – Accommodating the growth in employment opportunities that build upon our strong and diverse economy” does not require a Plan policy for existing residents of South Warwickshire. There is high employment how (136,000 jobs in 2026) and change in types of employment takes place over time without needing new greenfield development. This objective is derived from the proposed expansion in number of houses in the two Districts, which will bring net in-migration.

 

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Policy DS.2 (Strategic Policy): Publication (Regulation 19)

POLICY DS2 SPATIAL DEVELOPMENT STRATEGY

 

1. Policy DS2, Spatial Development Strategy, is the main policy that sets out the principal development proposed in the Plan. The Policy is at pages 39-41; the overall detail, explanation and justification appears to start at page 31, Para 2.3.1 (Title 2.3 ‘Calculating South Warwickshire’s Development Needs’ ) and continues through to the end of ‘Policy Justification’ at p43, para 2.5.18 (runs onto p44).

 

2. Policy DS2 lists (A) New Communities (2), (B) Strategic Housing Locations (16) and Strategic Employment Locations (3), (C) that there are Local Growth Locations (local sites listed in DS5, DS6 and DS7), and (D) Other Growth Locations, largely existing employment areas to be called Major Investment Sites.

 

3. Policy DS2 and, para 2.3.3 (p31) put the Plan Period as running from 2025 to 2050. This Plan Period is stated but not explained or justified. The Plan period for Local Plans is usually 15 years from time of adoption, so the Plan Period for the SWLP should be 2028-2043; or 2025-2043 with 2025 taken as base year and allowing three years to reach adoption.

 

4. Nowhere in the Regulation 19 Plan is there a clear justification for departing from the standard 15-year Plan Period. The Plan Period of 25 years – 7 years longer than is required – adds a large amount of development unnecessarily to the Plan.

 

5. There has been no public consultation at all on the length of the Plan Period. This basic question should have been put to the public at the Reg.18 Options stage: Do you prefer a Plan Period of 15 years ending in 2043 or a Plan Period of 22 years ending in 2050?

 

6. Failure to put this question to the public in the Preferred Options consultation is particularly harmful because the Plan was originally being prepared under previous planning policy with a demographically-based housing requirement, and a much lower housing requirement was expected with the Plan was first consulted on (Issues & Options stage). By the time that the Preferred Options consultation was held (Jan-March 2025) the present government’s ‘housing stock & affordability index’ method was in use (Dec 2024 NPPF Revision) and a policy target of 370,000 houses per year in England announced (also expressed as 1.5 million new houses in the present Parliament).

 

7. The change from the originally-envisaged housing need (LTN) which was the basis of the SWLP work when it started is very large.

 

PRE-DECEMBER 2024 (original SWLP basis)

 

Annual housing requirement

Stratford District: 553

Warwick District: 653

Total : 1206

Housing requirement: 18 years, 2025-2043: 21,700

Housing requirement: 25 years, 2025-2050: 30,150 (8,450 extra houses)

 

PRESENT STANDARD METHOD (May 2025 figure used in Reg.19 Plan)

 

Annual housing requirement:

Stratford District: 1,112

Warwick District: 1,085

Total: 2,197

 

Housing requirement: 18 years, 2025-2043: 39,500

Housing requirement: 25 years, 2025-2050: 54,900 (15,400 extra houses)

 

Fig 10 at p33 shows the ‘TO-FIND HOUSING NEED’ after allowing for existing commitments, which are 9,950.

 

Under the pre-December 2024 NPPF housing requirement shown above:

 

‘To-find’ figure for 15-yr Plan, 2028-2043: 21,700 less 9,950 : 11,750

‘To-find’ figure for 22-yr Plan, 2028-2050, 30,150 less 9,950: 20,200

 

Under the present Standard Method, May 2025 figure used in Reg.19 Plan:

 

‘To-find’ figure for 15-yr Plan, 2028-2043: 39,500 less 9,950: 29,550

‘To-find’ figure for 22-yr Plan, 2028-2050, 54,900 less 9,950: 45,000 (15,450 more)

 

 

8. The combined effect of changing from the pre-Dec 2024 demographic-based housing requirement to the present Standard Method aimed at delivering 1.5m houses in the present Parliament and (without public consultation) choosing a 22-year instead of 15-year Plan Period is to impose a requirement to find sites for 383% more houses than at the starting point of the Plan, when a 15-year Plan Period could have been chosen and the annual housing requirement was realistic and deliverable. The extra housing sites ‘to-find’ under the Standard Method because of the unnecessary extension of the Plan Period is a 52% increase.

 

9. The Plan’s housing requirement (total housing need, 25-year plan period) is based on a wholly unrealistic assumption: that the current Standard Method will remain in place for the next 24 years, through 5 Parliaments and probable changes of government and planning policy. The statement at p33, para 2.3.5 offers some caution: “Whilst it is acknowledged that there will be some fluctuation in the figures, it is unlikely that they will change substantially. Given the requirement to review plans every five years, the plan review will be the opportunity to reconsider the housing figures for South Warwickshire to ensure that the SWLP remains up-to-date and an appropriate strategy for meeting our housing needs. Fundamental change in the numbers, for example, arising from a change in methodology, could warrant an earlier review.”

 

10. This statement foresees that Plan reviews will take place every five years (as the NPPF requires), and that there could be a ‘fundamental change in the numbers’, if the methodology changes. Since there was a change in methodology two years ago, in Dec 2024, and this led to a fundamental change in the numbers in the SWLP as it was emerging, the Plan should recognise that there could be another fundamental change in the numbers within a few more years.

 

11. This caution is not reflected in the approach taken in the Plan. It seeks rather to lock in the present high annual housing requirement to last for the Plan Period, by allocating large sites which need many years to be completed. To reflect what para 2.3.5 says, and to avoid over-commitment when developments may prove unnecessary, there needs to be Phasing. Phasing of housing site starts would ensure that only the housing necessary for the first five years is permitted. Sites in later phases would not be granted planning permission in advance of when the Phasing requires them to be started; if a change in the housing requirement makes them unnecessary, they can be deleted from the Plan.

 

12. In the Plan as published there is no Phasing at all. The two Housing Trajectories, Fig 14 p52 and Fig 15 p53, show that most Strategic Growth Locations are expected to start on site at the same time, years 2028/29 to 2030/31. (The one notable exception is COV1, 2040/41 start, although that was included in the current Warwick District Local Plan in 2017 – the King’s Hill location, on which no work has started.)

 

13. The justification offered by the Planning Policy staff for the extended 2050 Plan Period has been that the standard Plan period would mean not being able to plan the larger scale developments and infrastructure, and would impact on the ability to deliver larger settlements, which would be difficult (or not possible) with a shorter-term plan in place. More of the smaller developments would come forward, displacing the larger sites, so the Councils would not be able to provide the infrastructure they are looking for. The NPPF states in relation to proposing new settlements and larger strategic growth locations, such as in the SWLP preferred options, plans should look to a longer timescale to 30 years than the minimum plan period to take account of likely timescale for delivery. (This has been more or less the same justification from the Local Plan policy staff whenever they have been asked.)

 

14. This justification bases itself wholly on the claimed need for South Warwickshire to have imposed on it large new settlements and large strategic housing locations on greenfield sites extending existing towns (typically 1,000 houses or more). If new settlements and large strategic housing locations are not necessary, or can be greatly reduced in number, the normal 15 year Plan would be the right Plan Period. It is the choice of the long Plan Period to 2050 (without public participation on this question) that creates the need for the Plan to propose so much larger scale development and infrastructure. The extra housing requirement that under the Standard Method results from setting the Plan end-date as 2050, 15,400 houses, creates the ‘need’ to propose so many large developments on greenfield and notably Green Belt land, with costly infrastructure.

 

15. The bias in the Plan towards more urbanisation of South Warwickshire and gradual loss of its mainly rural and small-town character is confirmed in Section 2.5.5, ‘Development Strategy’. This states, ” The new settlements also provide the foundation for sustainable growth beyond 2050, providing certainty to communities in the long-term as well as enabling a continuation of housing delivery across South Warwickshire”. This confirms that the bias of the Plan is a long-term policy of large urban areas, which can continue to grow beyond the extent shown on the Policies Maps, the opposite of what public participation has favoured: maximising use of land in existing towns, converting commercial floorspace (notably upper floors in shops) to residential use, restricting urban development, maintaining greenfield land and the Green Belt, and preventing loss of the essentially rural character of most of present-day South Warwickshire. Para 2.5.5 asserts that “The focus on strategic growth locations also helps to preserve the wider rural character and landscapes of South Warwickshire, by rightly limiting growth in these more sensitive and inaccessible locations”. This is achieved to some extent, by avoiding development (except on small sites mostly to meet local need) In villages and small towns (at Shipston-on-Stour, in southern and eastern parts of Stratford District, and in the villages along the foot of the Cotswold (Edgehill) scarp). But it is not achieved in the lower Avon valley at Bidford, the Alne Valley around Henley-in-Arden (a key area of countryside lying between the Birmingham conurbation and Stratford-upon-Avon), the wider setting of Charlecote Park (Wellesbourne’s expansion), the green meadowland east of Southam overlooked by the windmill-topped Napton Hill, and the eastern approaches to Stratford, where there seems no limit to the potential sprawl of housing. The pre-Dec 2024 housing requirement, based on demographic projections, would enable the achievement of this aspiration, but the high housing numbers imposed by the Standard Method and the extended Plan Period prevent it.

 

15. The effect of limiting the Plan period to 15 years is to enable substantially fewer strategic growth locations to be deleted and the Hatton ‘new community’ to be dropped. CPRE Warwickshire has produced and circulated details of how this can be done. See statement and tables attached. The proposed housing locations with their individual housing numbers that can be removed from the Plan are shown below.

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SOUTH WARWICKSHIRE LOCAL PLAN Regulation 19 Draft Plan

C P R E WARWICKSHIRE PROPOSALS

 

Large housing allocations that can be withdrawn from the Plan by limiting the SWLP to 15-year Plan Period instead of 22 years. (Plan adopted 2028; standard plan period 15 years; end date of Plan 2043 instead of 2050.)

 

Annual housing target:

Stratford District 1,112 houses/year

Warwick District 1,085

SWLP whole area 2,197

 

For 25 years 2025 to 2050: 54,925 houses

For 18 years 2025 to 2043 (7 years less) 39.546

 

Reduction in housing requirement in SWLP area by adoption of a 15-year plan period: 15,379

 

Housing sites to delete in: Warwick District

 

Hatton (near Hatton Station) HAT – 4,000

South of Kenilworth KEN1 – 776

Blackdown (Leamington)LEA1 – 1,043

Old Milverton LEA2 – 974

East of Lillington LEA3 – 1,455

 

Total in Warwick District: – 8,248

 

Housing sites to delete in: Stratford District

North of Henley-in-Arden HEN – 2,084

East and NE of Southam SOU1 – 3,122

North of Wellesbourne WEL1 – 1,331

Bidford (partial reduction) BID1 – 650

 

Total in Stratford District – 7,187

 

Total Reduction in South Warwickshire Plan area: -15,435 reduction in total housing in SWLP area

 

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16. Other parties may have alternatives to this set of proposed deletions.

 

17. Thus the effect of a 15-year Plan Period is to remove the need for 15,400 houses and avoid the cost and resources involved in building substantial new infrastructure on greenfield (notably Green Belt) sites (around Leamington, Kenilworth, and outside Henley-in-Arden). The Hatton ‘New Community’, which will require very costly infrastructure, becomes unnecessary. Large-scale housing development at some unsustainable locations where services are limited and small original settlements would be overwhelmed by new housing would be avoided: at Southam (small town with limited services), Wellesbourne (village already overbuilt with new housing despite few services) and Bidford (large village with some small-town characteristics but limited services).

 

18. The extra length of the Plan Period has damaging effects on the environment through loss of greenfield and notably Green Belt to housing. This makes the Plan unsound.

 

19. The employment land proposals are limited. Two of the main locations, COV2 Coventry Airport and Gaydon/ Lighthorne Heath GAY1, are existing industrial sites in the adopted Plans. The Warwick District part of the Airport location is already allocated as DS16 in the Warwick District Local Plan, with much of the land as yet unused. The Gaydon industrial location looks excessive, yet an extension south of the existing allocation has been recently allowed on appeal.

 

20. The large employment land proposal BIT2 around the A425 with proposed new M40 Motorway Junction at Red House Farm is not desirable. It appears to be based on the West Midlands Strategic Employment Sites Study (WMSESS), which while part of the evidence base has no status as a planning policy document. It appears that if allocated BIT2 would become mainly a site for B8 uses, warehousing and distribution. The WMSESS estimated that 75% of new floorspace on the ‘road-based’ strategic sites could be taken by B8 uses and only 25% by B2 (manufacturing). This form of employment is low-paid and job density relative to floorspace is low. The population characteristics of Warwick and Leamington mean that the jobs in warehousing and distribution on the BIT2 site would not be taken by local residents; they would be filled by people bussed-in from lower-income areas or filled by migrant workers. (This is a characteristic of employment in the Rugby area’s B8 warehouses, and at Magna Park in the Harborough District in Leics.)

 

21. The BIT2 development would tend to become dominated by B8 uses, which would both be of low utility to the local economy and result in ‘big box’ large structures. These would harm the setting of the Grade II* Registered Warwick Castle Park, already degraded by the recent housing between Europa Way and the Banbury Road into Warwick.

 

22. The aim of the BIT2 proposal is given as to ‘meet the strategic employment needs of South Warwickshire’. ‘Strategic needs’ are not defined, but have been explained in the on-line consultation presentations as land to attract ‘inward investment’. Large inward investment locations tend to be oversupplied in Plans as local authorities compete to offer such sites. The result is that only some are taken and to find a user the standard can be dropped, resulting in most development being of the ‘big box’ character. Unless the BIT2 location is limited to B2 and E(g) use classes, and B8 is not permitted on it, its location at a motorway interchange will make it a warehouse and distribution park, of no use to the local economy, offering employment that the population of Warwick and Leamington will not want to take, intrusive to the local area, and a generator of heavy lorry movements.

 

 

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POLICY DS3 (Strategic Policy): Publication (Regulation 19)

Section: Policy DS.3 (Strategic Policy)

CPRE’s objections to Policy DS3 are as stated in representation on Policy DS2 which covers some of the same ground, so are not repeated in detail in response to DS3.

 

The Plan has very high housing numbers – 54,900 houses – because it is to run until 2050. There is no need for it to do this (see representation on DS2). Changing the Plan period to 15 years reduces the number to 39,500. 8,000 houses can be cut from the numbers being imposed in Warwick District and 7,500 from Stratford District’s total. The Plan period should be shortened to 2043.

 

This as explained in representation on DS2 will enable to remove from Stratford District the proposed housing east of Southam and north of Wellesbourne, the 2,000-house plan in the Green Belt north of Henley in Arden, and 650 houses of the allocation at Bidford on Avon. In Warwick District, the Green Belt housing sites at Hatton Station (HAT, 4,00 houses), on land south of Kenilworth (KEN1) and the Green Belt areas around Leamington at Old Milverton (LEA2), Blackdown (LEA1) and east of Lillington (LEA3) can be deleted.

 

LMA (which is large-scale sprawl) should be replaced by a smaller, more compact housing development on the former Long Marston Military Depot land.

 

The 4,000 houses proposed on the south west edge of Coventry, mainly in Burton Green Parish, should be accommodated inside Coventry instead.

 

See CPRE’s calculated reduction in housing numbers below.

 

Regulation 19 Draft Plan Large housing allocations that can be withdrawn from the Plan by limiting the SWLP to 15-year Plan Period instead of 22 years (2025 to 2050) (Plan adopted 2028; standard plan period 15 years; end date of Plan 2043 instead of 2050

 

Annual housing target: Stratford District 1,112 houses/year

Warwick District 1,085

Total annual target – SWLP whole area 2,197

 

For 25 years 2025 to 2050 : 54,925 houses

For 18 years 2025 to 2043 : (7 years less) 39.546

 

Reduction in housing requirement in SWLP area:

 

By adoption of a 15-year plan period: 15,379

Housing sites to delete in Warwick District Hatton (near Hatton Station) HAT – 4,000

South of Kenilworth KEN1 – 776

Blackdown (Leamington) LEA1 – 1,043

Old Milverton LEA2 – 974

East of Lillington LEA3 – 1,455

 

Total in Warwick District: – 8,248

 

Housing sites to delete in: Stratford District

 

North of Henley-in-Arden HEN1 – 2,084

East and NE of Southam SOU1 – 3,122

North of Wellesbourne WEL1 – 1,331

Bidford (partial reduction) BID1 – 650

 

Total in Stratford District – 7,187

 

Total Reduction in South Warwickshire Plan area: -15,435 reduction in total housing in SWLP area

 

This is one option for reducing greenfield housing sites with a 15-year SWLP Plan Period. Others may offer different combinations of sites to delete.

 

 

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Policy DS4 (Strategic Policy): Publication (Regulation 19)

DS4 STRATEGIC SITE PRINCIPLES

Policy DS4 sets out principles for new settlements and strategic growth locations. The Policy justification for this Policy is that these are necessary, and (para 2.6.2) “will play a key role in delivering the spatial growth strategy of the South Warwickshire Local Plan”.

Para 2.6.4 explains that “new settlements are intended to provide the foundation for growth beyond 2050″and “are the focal point for the delivery of housing growth in the South Warwickshire Local Plan”. They are required to deliver comprehensive on-site infrastructure to serve the needs of residents, including education, healthcare, employment, retail and community facilities.

Neither the proposed number of strategic growth locations (SGLs) nor any new settlements would be needed in the Plan but for the 83% increase in housing requirement imposed in the Dec 2024 NPPF, compared to the level set in the pre-2024 NPPF (which was 1206/year). The Hatton new community and some of the SGLs would not be needed if the current annual housing requirement was in force but the Plan Period was the normal 15 years not 22 (to run to 2050). They introduce forms of urban development which are out of character with the rural areas which they will urbanise. The aim to integrate them with the landscape [DS4(a)(1)] is laudable but not achievable – they are urban development, in places at a high density, with all the distinctions from countryside that it creates.

The need for these settlements and the stress laid on their role shows that the current imposed housing requirement is not compatible with the maintenance of the existing pattern, and balance, of towns and rural areas in South Warwickshire. To meet it requires major extension of present towns and two large villages, and location of a new settlement in the Green Belt in wholly unsuitable country for one.

Recent urban extensions approved through past Local Plans have not enhanced the landscape and have not fitted into it. This is shown by the impact of new housing sites on three sides of Southam, those on the southern extension of Wellesbourne east of the A429, the west side of Stratford, the Shipston Road south of Stratford, and development on the west of Shipston-on-Stour (Chipping Campden Road). The urban road layouts, lighting and standard types of housing give these extensions a form that does not integrate with the landscape.

 

 

Change to plan sought:

The number of Strategic Growth Locations should be substantially reduced. The Hatton new settlement should be dropped. At Long Marston, the current LMA housing development should have limits placed on its further expansion, and instead of the large (up to 9,000 houses) LMA new settlement proposed, the earlier proposal (2007-09) for Long Marston Depot to be a full new settlement (up to 6-7,000 houses) should be returned to. That location should be included in the Plan. It is to a large extent a brownfield site.

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Policy DS.7 (Strategic Policy): Publication (Regulation 19)

POLICY DS7 LOCAL GROWTH LOCATIONS – HOUSING

CPRE Warwickshire opposes certain of the Local Housing sites proposed under DS7.

ALC2 Alcester 79 houses in Green Belt on NE side of town. No exceptional circumstances for taking land out of Green Belt.

BAR2 Barford – 122 houses on land east of Wellesbourne Road – this extends built-up area which should end at present point.

GAY3, GAY8, GAY9, GAY10 – sites for housing around Gaydon village. Total housing likely to be 378 houses. This is a huge imposition on a small village which has to live with the extensive Gaydon – Lighthorne Heath new settlement and employment development. GLH was imposed on Gaydon in the Stratford Core Strategy a decade ago. The village will lose all character and be overwhelmed by 378 houses, more than the number of houses there today. The Local Plan is supposedly avoiding locating new housing in rural villages, with only local housing needs being met by small sites. Gaydon should be treated under that category and not as if it is part of the GLH new settlement area.

KIN2, KIN3, KIN4 – A total of 158 houses proposed at Kineton. Kineton is defined in the Plan as a ‘small town / large village’ or local service centre. This is much more than are required to meet local needs and the village has already accepted significant new housing. Its character will be lost if more housing than is shown as needed by local needs assessment. All local traffic passes through the historic village centre and 158 more houses will make the traffic there high enough at times to discourage walking in the street and local community activities.

SHI1 to SHI7 – 7 housing sites proposed at Shipston-on-Stour – a total of 542 houses, with three sites each over 100 houses. A proposal for a development east of the River Stour of 1,000-plus houses was an option at the Reg.18 consultation but is thankfully not included in the Reg.19 Plan. Shipston is an unsustainable location for more than small developments, being remote from many services and having little public transport. The same grounds for rejecting new housing apply to the larger of the SHI 1-7 sites. Reasonable local needs can be met with 130-150 houses. The town has already grown excessively to the west along Chipping Campden Road. Most of these proposed sites should be deleted.

ST1 and STU3 – these are housing sites proposed on what is now Green Belt on the south-west side of the A448 Bromsgrove Road, the main road between Alcester and Redditch. The A448 has been an effective Green Belt boundary and the land to the southwest of it is in Sambourne Parish. These two sites would put 353 houses on the wrong side of the main road from their services in Studley, add many more houses to Sambourne than it now has, and partly fill the important gap between Studley and Sambourne. They should be deleted.

WEL2, WEL3, WEL4 – these together would create an extension southwards of Wellesbourne in a location well away from the village’s (limited) services, where there is a historic house and an ancient woodland close by. This location was the subject of an appeal refusal on landscape grounds. These three sites would together add 198 houses to Wellesbourne, which is also affected by the large WEL1 housing proposal. They should be deleted.

 

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Chapter 8:  Housing Site Proposals   (See also Policy DS2)

Housing Site Proposals (Strategic Growth Locations)

 

CPRE Warwickshire objects to the following Site Proposals:

 

HAT – Hatton New community. This should be deleted.

 

BID1 – Bidford on Avon – proposal is to reduce this by 650 houses to make it fit better to the existing urban area

 

BIT1 – Land West of Greys Mallory roundabout

 

BIT2 – Industrial land south of Greys Mallory and north of M40 plus new motorway junction – the development here would bring mostly B8 warehouse and distribution uses which are not required in the Warwick/Leamington area

 

BIT3 – Land southwest of Bishops Tachbrook – this should be cut back to the western part only, or the requirements of the Policy changed to ensure that the listed barn is used as a community or service building as part of the development

 

HEN1 – This should be deleted as contrary to Green Belt policy and not a sustainable location

 

KEN1 – Objections – see Objection to Green Belt policy DS13.

 

LEA1, LEA2 – Objection- see objections to Green Belt policy DS13

 

LEA3 – Objection – see objections to Green Belt policy DS13

 

LMA – Objection. This proposal is damaging to the countryside because of its large scale, harm to nearby villages and the landscape, and generation of road traffic. It should be replaced with a denser new settlement on the Long Marston Depot site, extending Meon Vale, as was proposed in 2007-2009 but dropped when the then ‘Eco-town’ programme was withdrawn.

 

SOU1 – The large extension to the east of Southam is for an unsustainable development.

 

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Policy DS.9 (Strategic Policy): Publication (Regulation 19)

DS9 CORE OPPORTUNITY AREA

DS9 states “The Core Opportunity Area (as shown on the Key Diagram) will be the focus for new employment development in the South Warwickshire area and proposals for commercial, business, research and industrial development within this area will be encouraged….”

There is no notation for the Core Opportunity Area on the Key Diagram or on the similar diagram shown with the text of Policy DS9, and it is not shown on the Policies Map. It is not clear what the area is. The policy is vaguely explained at para 2.9.2: “The South Warwickshire Economic Strategy identifies a Core Opportunity Area as a way of attracting inward investment into South Warwickshire….” But the area indicated is rural, south of Warwick/Leamington, and has no major settlement apart from Stratford itself. Why it is necessary to attract more inward investment into that area is quite unclear.

Change to plan:

Delete Policy DS9.

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Policy DS.10 (Strategic Policy) : Publication (Regulation 19)

 

POLICY DS10 MAJOR INVESTMENT SITES

Proposal MIS.B states: “B. Long Marston Rail Innovation Centre (Proposal MIS.B): The Long Marston Rail Innovation Centre will be safeguarded for rail-based and rail-related employment, research and investment including supply chain uses, as the UK’s only looped standard gauge test-track. The operational rail connection to the national rail network will also be safeguarded.”

Long Marston Rail Innovation Centre has relatively small research floorspace and there is no rail manufacturing there. The main feature is the looped test track which can be used for continuous running. Much of the site is used for storage of off-lease or withdrawn fleets of trains, mainly electric multiple units. This is not an intensive use and provides a relatively small level of employment. The best-known use of the Innovation Centre is the annual Rail Live exhibition every June.

The overall Long Marston Depot site (LMD), of which this forms part, would be better used as the location for the Long Marston new settlement, replacing LMA. In 2007-09 it was proposed as a new settlement under the then government’s ‘Eco-Towns’ policy. Because that policy was dropped in 2009, the case for locating the new settlement at LMD in place of LMA in the Core Strategy was not made.

 

Change to plan:

Amend Proposal MIS.B to state that the LMD location would be a suitable location for the new settlement which is proposed in the Plan to be at LMA (and sprawling over agricultural land beyond the old airport perimeter).

 

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Policy DS.13 (Strategic Policy) : Publication (Regulation 19)

DS13 GREEN BELT – ALTERATIONS TO GREEN BELT THROUGH THE SWLP

The Plan proposes to inset some villages now washed-over by Green Belt status, and to change Green Belt boundaries around some settlements. These changes to the West Midlands Green Belt are opposed as unnecessary and as undermining the purpose and strength of the Green Belt.

The Green Belt in Warwick and Stratford Districts has been very effective over some 70 years, particularly since it was generally confirmed by Ministers in 1975. It has fulfilled its purposes by controlling development, preventing urban sprawl, saving the countryside from encroachment, and shaping the pattern of towns, villages and countryside. It has kept open and as rural the part of Warwickshire between the county’s main towns (in a crescent, Alcester, Stratford, Warwick, Leamington, and Rugby) and the cities of Birmingham and Coventry. Urban areas within the Green Belt have been contained and not allowed to merge with larger neighbours (Kenilworth with Coventry, Studley with Redditch).

This width of the Green Belt has been an asset not a liability. It ensures that the distance between the ‘crescent towns’ and the cities is enough to ensure that countryside and villages between them are preserved, while being crossed by rail line enabling sustainable travel between the town and the cities. The restoration of local rail service between Leamington, Kenilworth and Coventry has assisted in maintaining this role.

SWLP Para 2.10.3 states: ” Exceptional circumstances exist which justify making changes to Green Belt boundaries. These boundary changes are necessary in order to deliver a sustainable spatial growth strategy, locating housing and employment growth in the most appropriate locations. The pattern of existing larger settlements and public transport infrastructure in South Warwickshire means that many of the most sustainable locations fall within the Green Belt. The Green Belt releases align with and underpin the Development Strategy (see Section 2.5 above) and are critical to its success.”

This assertion does not fit the facts. The major employment locations proposed are not in the Green Belt; they are beyond its outer boundary (BIT 2 and G-LH). The exception, the proposal for local employment land at Stoneleigh (STO1 and 2) is unclear as to its purpose as COV2 and COV4 are close by and already allocated. The controversial proposals in the heart of the Green Belt, HEN1 at Henley in Arden and HAT at Hatton, are not sustainable locations. A local train service (hourly or less frequent and even less on Sundays) is not a basis for a sustainable strategy; nearly all journeys by their residents, including most journeys to work and shopping trips, would be by car. Local bus services inside them would not be viable, and any settlement of that size will be car-focussed.

The proposals to take land out of the Green Belt on the north-western and north-eastern sides of Leamington (LEA1, LEA2 and LEA3) and from the south-west side of Kenilworth (KEN1) would result in housing on land further from the two town centres than is most of their current development. It would not be development dense enough to make viable a frequent bus service, and the road access plans for these locations have not been devised for bus services. The effect of the LEA1 and LEA2 allocations when taken with the releases of Green Belt on the south-east side of Kenilworth under the current Local Plan would together reduce the gap between Leamington and Kenilworth very significantly, from 3.8 km(2,5 miles) to 2.4 km (1.5 miles), or from 16 fields width to 10 fields.

The most sustainable way to deliver the Development Strategy of the Plan is to locate more development in the older parts of the main towns, which are the most sustainable locations and maximises access to employment, both local and (by rail commuting) in the cities. The land now in the Green Belt which it is proposed to release and develop will create more car travel, more car dependency, and be harmful to environmental and climate change objectives.

Policy DS13 also proposes to remove some small villages from the Green Belt. Bubbenhall, Claverdon, Hatton Station, Snitterfield, Tanworth and Wilmcote would become insets. Washed-over status is justified where villages include open areas, are not nucleated and can stretch out (eg. in a linear form), and where a boundary around them cannot be drawn without putting at risk open land in the village. Also, Conservation Area status is better maintained when a village is washed-over. These villages have been found to justify washed-over status in past plan reviews and there has been no public consultation on the proposal to make them Insets. This element of Policy DS13 should be withdrawn.

Change to plan:

Remove from the Policy parts (a) – list of villages to be inset, and (b) the list of new settlements and SGLs which would be on land released from the Green Belt; apart from COV2, Coventry Airport, which has redevelopment already underway.

 

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Policy ID.3 (Strategic Policy): Publication (Regulation 19)

ID3 PROTECTING ROUTES FOR INFRASTRUCTURE

This policy is sound in principle. But for (A) Railway-related schemes, A1-3 covering Stratford-Long Marston (former Birmingham-Stratford-Chelthenham main line) needs to be revised and strengthened.

It should be a policy to reopen this line during the Plan period, and to build a station at Long Marston Depot (LMD). LMA as the location for new settlement should be replaced by LMD, in effect reviving the proposal of 2007-09 which was withdrawn whern the ‘Eco-town’ policy was dropped during the global banking crisis of 2008-11

On the proposal for a Stratford (Western) Bypass, see ID4.

Change to plan:

Revise the wording to include the policy to reopen the Stratford-LMD line and provide a new station at LMD, not LMA.

 

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Policy ID.4 (Strategic Policy): Publication (Regulation 19)

ID4 Stratford-upon-Avon Bypass

CPRE Warwickshire objects to the proposed Stratford Bypass as shown on the Policies Map and described in Policy ID4. This proposal would be damaging to the rural Luddington Parish, in effect splitting the village. The reach of the River Avon which would be crossed by the route shown on the SWLP Policies Map is particularly attractive and is navigable, and used by many canal and river users.)

The studies for this scheme have been progressed in secret and there has been no public participation yet on the need, on alternative routes and on alternative ways to serve the Long Marston area – notably, reopening of the Stratford-Long Marston line.

Change to plan:

The Policy should require full public participation on the need for this road scheme and alternative routes and alternative transport solutions to it.

 

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Policy ID.21 and ID.22 (Strategic Policy): Publication (Regulation 19)

ID 21 and ID22 New Large Scale Renewable Energy Generation and Storage and requirements

Policy ID21 is not strong enough in protecting the landscape of South Warwickshire, views from higher ground and viable agriculture. It may place support for renewable energy (solar farms, wind farms) and battery storage over protection of the landscape and its character. Wind turbines, solar arrays in fields and BESSs are industrial impositions. Solar arrays on industrial and commercial roofs should be supported instead; these are not mentioned in the Policy. Only by preventing solar on farm and open land will it be placed on roofspace. The Policy should be strengthened to give priority to roof solar and resist solar on farmland.

Policies ID21 and ID22 are not compatible with protecting the landscape of South Warwickshire, views from higher ground and viable agriculture. They give support for renewable energy (solar farms, wind farms) and battery storage (BESS) over protection of the landscape and its character. Wind turbines, solar arrays in fields and BESS are industrial artefacts..

Policy ID21 (c) states that proposals for renewable energy generation and storage will be supported where they provide for a community benefit. This is contrary to the law: community benefits, including financial or social benefits, are not material planning considerations and it is unlawful to take them into account or use them as justification for permitting a windfarm or solar farm. See Supreme Court 2019 Judgment: R (Wright) v Resilient Energy Severndale Ltd and Forest of Dean District Council [2019] UKSC 53

Solar farms have been permitted in parts of South Warwickshire. There is a group of solar farms south-east of Leamington, which take up good agricultural land and damage recreational value of footpaths. Their extent and the degree to which the countryside has been changed can be seen in an OS extract map attached.

The Policy states that solar will be supported on Grades 1, 2 and 3a land if it ‘does not restrict the agricultural use of the land’. Solar arrays do restrict – indeed prevent – the use of land commensurate with its Grade – and apart from sheep grazing in some case from any agricultural use at all.

Solar arrays on industrial and commercial roofs should be supported instead. Only by preventing solar on farm and open land will it be placed on roofspace. The Policy should give priority to roof solar and resist solar on farmland.

Wind turbines are industrial artefacts which by their form visually do not fit into rural landscapes; they draw the eye, and are intrusive. They are compatible with industrial locations and where there are groups of pylons (not single power lines).

Under Policy ID21, Proposals are required to contribute positively to, and take  account of, policies in respect of:

• Landscape character and visual amenity
  Historic environment, including the setting of heritage assets
  Biodiversity net gain and ecological networks
  Green and Blue infrastructure

It should be recognised that neither wind turbines nor solar panel arrays on farmland can contribute positively to landscape character and visual amenity.

BESS (Battery Energy Storage Systems) are industrial artefacts. They are not renewable energy, and are used for electricity trading in the electricity market by their operators. They are suitable for industrial estates and next to industrial and commercial buildings. Policies ID21 and ID22 should be amended to state that BESS will not be permitted in open countryside or on any farmland; they should be located on or next to land in existing or proposed industrial or distribution use (Use classes B1 and B8).