Q-S3.1: Please add any comments you wish to make about the Urban Capacity Study

I believe that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non-greenbelt brownfield or greenfield sites, these should be actively sought out. The consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. Appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

The study would appear to potentially over-estimate brownfield capacity because it includes capacity on existing new settlements which could have been greenfield. In addition, the inclusion of windfall capacity does not necessarily take place on brownfield land. The urban capacity title is a little misleading because of these points. The future supply of windfall capacity is not fixed and has potential to be influenced by planning policy. Since windfalls tend to occur on smaller sites this can be an important future resource that can reflect, as examples, market demand, self-build and permitted development (such as Class Q conversions). There is potential for this to be used a deliberate strategic component of future housing land supply. Inclusion of the windfall analysis within the urban capacity study suggests the scope of this source has not been fully considered.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

As a theoretical exercise and not one to establish the true urban capacity of south Warwickshire I fail to see the usefulness of this study. The true urban capacity of South Warwickshire needs to be established and the viability of developing these sites must be prioritised before even contemplating developing green field sites

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In see particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non-greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority. Brownfield development uses land which has previously been in use; with de - industrialisation especially (But nor exclusively) in the Coventry area, there is room for infill in many location which should be identified more rigorously. It would seem that Development sees Green Belt building as the "easy way, and needs more serious thought.

The study would appear to potentially over-estimate brownfield capacity because it includes capacity on existing new settlements which could have been greenfield. In addition, the inclusion of windfall capacity does not necessarily take place on brownfield land. The urban capacity title is a little misleading because of these points. The future supply of windfall capacity is not fixed and has potential to be influenced by planning policy. Since windfalls tend to occur on smaller sites this can be an important future resource that can reflect, as examples, market demand, self-build and permitted development (such as Class Q conversions). There is potential for this to be used a deliberate strategic component of future housing land supply. Inclusion of the windfall analysis within the urban capacity study suggests the scope of this source has not been fully considered.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritsed and that where Brownfield development is not possible, then development should not occur in Greebelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Gree nbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

I feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, I do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

I feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, I do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

We feel that the use of brownfield sites should be prioritised and that where brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non-greenbelt brownfield over greenfield sites. These non-greenbelt brownfield sites should be actively sought out. We feel the consultation document is heavily biased towards development in the greenbelt north of Leamington and this should be avoided, especially when as much as 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

Urban Capacity Study: We feel that the use of Brownfield sites should be prioritsed and that where Brownfield development is not possible, then development should not occur in Greebelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritsed and that where Brownfield development is not possible, then development should not occur in Greebelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

Urban Capacity Study: We feel that the use of Brownfield sites should be prioritsed and that where Brownfield development is not possible, then development should not occur in Greebelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

The South Warwickshire Urban Capacity Study is a useful document that confirms the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements could be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. l. In addition, a number of brownfield sites may not be suitable for residential development on viability grounds, or will be unable to support a “normal” S.106 package and result in reduced contributions towards affordable housing. This could be exacerbated by the introduction of NDSS standard housing and the other requirements of the emerging plan. Furthermore, the study does not consider the capacity of existing infrastructure to accommodate development, for example education and health. There may be infrastructure constraints that prevent some sites being developed, or a lack of service and facilities nearby that make sites unsustainable locations for residential development. There is currently insufficient information available to establish the role brownfield sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance.

The South Warwickshire Urban Capacity Study is a useful document that confirms the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements could be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. In addition, a number of brownfield sites may not be suitable for residential development on viability grounds, or will be unable to support a “normal” S.106 package and result in reduced contributions towards affordable housing. This could be exacerbated by the introduction of NDSS standard housing and the other requirements of the emerging plan. Furthermore, the study does not consider the capacity of existing infrastructure to accommodate development, for example education and health. There may be infrastructure constraints that prevent some sites being developed, or a lack of services and facilities nearby that make sites unsustainable locations for residential development. There is currently insufficient information available to establish the role brownfield sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance.

The South Warwickshire Urban Capacity Study is a useful document that confirms the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements could be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. In addition, a number of brownfield sites may not be suitable for residential development on viability grounds, or will be unable to support a “normal” S.106 package and result in reduced contributions towards affordable housing. This could be exacerbated by the introduction of NDSS standard housing and the other requirements of the emerging plan. Furthermore, the study does not consider the capacity of existing infrastructure to accommodate development, for example education and health. There may be infrastructure constraints that prevent some sites being developed, or a lack of services and facilities nearby that make sites unsustainable locations for residential development. There is currently insufficient information available to establish the role brownfield sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

The Study sets out that its purpose is to provide evidence that helps to reduce the need for development outside of South Warwickshire’s 23 existing urban areas as far as justifiably possible. Section 4.6 of the Study identifies that there is a total baseline housing supply for the 2025-2050 Plan Period of 19,950 dwellings, of which 6,145 would be located within existing urban areas. The Church Commissioners questions the robustness of this figure, as it is partially derived from development occurring on existing public car parks, which is not considered to be realistic. Notwithstanding, the Study then goes on to compare this supply against a housing need for South Warwickshire of 30,750 dwellings across the Plan Period. This figure is incorrect. The Consultation Document and HEDNA seeks to establish a ‘trend-based’ alternative to the Standard Method, which result in annual housing need of 868 dwellings per annum (Stratford) and 811 dwellings per annum (Warwick), totalling 1,679 dwellings per annum. Multiplied across a 25-year Plan Period, this need is in fact 41,975 dwellings. This figure is importantly also exclusive of meeting any unmet need arising from neighbouring authorities, such as Coventry or Birmingham. 3.19 The identified supply, inclusive of sites within existing urban areas, is therefore less than half of the overall housing need required during the Plan Period. This clearly therefore indicates a need to look to greenfield sites for development, such as Land at Long Marston Airfield.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

I feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, the "call for sites" approach does not sufficiently prioritise the Identification of non- greenbelt brownfield or greenfield sites, which should be actively sought. The consultation document is heavily biased towards development in the greenbelt North of Leamington, which should be avoided. An appropriately planned approach to development should, from the outset, seek to avoid the need for greenbelt development in "exceptional circumstances".

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.