Q-S3.1: Please add any comments you wish to make about the Urban Capacity Study
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.
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.
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.
I feel Brownfield sites should be the for development and should not occur in greenbelt. The document seems biased in its development in the greenbelt north of Leamington Spa. This should not be allowed. Greenbelt development should not be allowed, avoided as priority.
The urban capacity study identifies relatively little room for growth in the number of residential properties in existing urban areas. Nevertheless opportunities may arise over the life of the Plan. For example, a reduction in demand for office and retail space may provide opportunities to reuse these sites for residential use. However it should be noted that sometimes if ‘brownfield’ employment land is used for housing, ‘greenfield’ land may have to be allocated for existing businesses to relocate elsewhere. So brownfield development is not always the most environmentally friendly solution.
Brownfield first, before building on open green fields.
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 basel ine housing supply for the 2025-2050 Plan Period of 19,950 dwellings, of which 6,145 would be located within existing urban areas. Caddick Land queries 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. 3.11 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 a establish a ‘trend-based’ alternative to the Standard Method, which results in an 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. Importantly this figure is also exclusive of meeting any unmet need arising from neighbouring authorities, such as Coventry or Birmingham. 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 green field sites for development.
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 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 focusses on density as a quantified figure based on existing capacities, which is a helpful tool to ascertain the expected density for new developments in proximity of existing development. The study notes that proximity of constraints, including listed buildings or wildlife sites, are not fundamental to prevent development. This is the right approach. However, the limitations of the Urban Capacity Study are identified in the report, itself. The study is a theoretical exercise that is not intended to conclusively establish the urban housing capacity of South Warwickshire over the plan period. Instead, it indicates a current potential urban housing capacity. More detailed work is required to confirm actual capacities, especially when it is noted that the study has not been informed by the outcome of a HELAA. Directly linked to the Urban Capacity Study, further work should also be undertaken to ascertain the potential of incorporating a similar concept to the PTAL1 rate (density driven by proximity to public transport) in relation to urban areas. This would further encourage and guide development to sustainable locations and provide benefits for proposals with better PTAL rates (i.e. support for higher densities, reduced car parking requirements), or additional requirements for proposals with worse PTAL rates (i.e. additional car parking spaces, financial contributions) on a case-by-case basis.
3.16 We welcome and support the recognition at section 4.6 of the Urban Capacity Study that an identified capacity of around 19,950 compares to a housing need for South Warwickshire over the new plan period of 30,750. Concluding that, “whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development”. This report clearly demonstrates that the district authorities cannot meet their own housing need on previously development land while building at appropriate densities or utilising public car park sites. Given the scale of need that is expected to be unable to be met on previously developed land, this suggests exceptional circumstances exist to review the Green Belt.