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

Use Brownfield sites before building on open green fields

We would support development of brownfield sites as a priority, since this will return otherwise derelict areas to use, generally have little adverse impact on the environment. Such sites are often much better situated in relation to existing urban areas and services.

The study was commissioned based on using urban land efficiently. Unfortunately, I could find no reference to the Governments pledge to “Brownfield First” which guides District Councils in handling housing demand from adjacent Authorities, within either the Study Report or the main consultation. I am convinced that urban regeneration/brownfield land must be prioritised. Redeveloping brownfield land has the added environmental benefit of not only reducing the loss of green field sites/Green Belt, but also remediating the brownfield land, often bringing it back into economic use. Residential development in Green Belt pulls affordable housing provision away from towns and cities where such demand is usually greatest, being close to places of work. Brownfield sites are usually within existing settlements, in sustainable locations close to public transport, places of work, and can often accommodate higher density housing. I would support that target development densities are at the highest possible appropriate level. The high cost of remediation is often raised against the viability of developing on brownfield land, however perhaps consideration could be given to some way of subsidising of the brownfield remediation works, (possibly through a differential in CIL or similar contributions between Greenfield & Brownfield land, which would make Brownfield land redevelopment more attractive to developers.

The Government has also made a “brownfield first” pledge (see letter above) which should inform the way that the District Councils respond to unmet housing need in other authorities. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit.

I believe that site 592 (STR.18) is incorrectly designated as brownfield. Having the correct designation is crucial and should be proven.

The Urban Capacity study should be given high priority. Development of greenbelt to address the housing crisis represents an unimaginative and misinformed view that regeneration is costly and unappealing. Urban sprawl is low density . It is a resource hungry and inefficient use of land. Proposed land for development should be put forward in line with the National Planning Policy Framework. Proposals to develop Greenbelt land are an inappropriate and unimaginative response by Local Authorities to pressure to propose land for development.

It skews development away from affordable housing in the areas where people work. The Government has also made a “brownfield first” pledge (see letter above) which should inform the way that the District Councils respond to unmet housing need in other authorities. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit.

HOUSING DEVELOPMENT ON BROWNFIELD SITES SHOULD BE PRIORITISED OVER ANY OTHER HOUSING DEVELOPMENT OPPORTUNITIES

It skews development away from affordable housing in the areas where people work. The Government has also made a “brownfield first” pledge (see letter above) which should inform the way that the District Councils respond to unmet housing need in other authorities. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit.

No matter what the local community want the Council, will ignore community comments and wishes if it go against the Council.

The use of brownfield sites should be prioritised and where brownfield development is not possible, then the development should not be on greenbelt land. The 'call for sites' approach does not sufficiently prioritise the identification of non-greenbelt brownfield or greenfield sites, whereas these should be actively sought out. The consultation document is heavily biased towards development of 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 should be avoided as a 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, 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 use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greebelt land. In particular, I do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, which 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 apart from in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

Concerning argument 7, the brownfield first pledge must be given much greater emphasis rather than the easy but hugely damaging and detrimental building on green belt land that the plan advocates.

When referring to brownfield, it is worth bearing in mind that old farm buildings, stables and land previously used for farming is not, and should not, be considered as brownfield.

I believe brownfield land should be prioritised over greenfield land to develop and meet future housing needs.

The most popular sites that have come forward are greenfield sites where developers have landbanked and are trying to cash in. There are many underutilised brownfield sites that don't appear to have been put forward. WDC should proactively approach the owners and compulsory purchase them if necessary.

One of the stated purposes of Green Belt land is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. The Urban Capacity Study is a good starting point in this regard but should go further and make clear that this should be the primary route for development (in line with the Government's “brownfield first” pledge). Unfortunately, the scope of the five spatial growth options runs completely counter to this by putting a majority of development on Green Belt land. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit.

In a post-covid age where the importance of conserving green space and greenbelt land has become so very starkly apparent to everyone, the logical extension is that brownfield sites should always be developed first, even if this is inconvenient to developers or less profitable for them. The idea that developers should even be able to consider developing greenbelt land before reclaiming all existing brownfield sites seems extraordinary doesn't it?

Have all brownfield land options in all towns been fully exhausted? the Green Belt land to the north of leamington fulfills all 5 of the green belt purposes and is precious farm land. it should not be developed.

The Study has been done in recognition of 'the need to use urban land efficiently'. The 'Brownfield First' pledge is not referenced in the study or the main consultation and should be explicitly referenced alongside a recognition that Green Belt land does not have to be released simply because numbers are not easily accommodated elsewhere.

Detailed comments on the Urban Capacity Study are set out in CPRE's submitted report on Housing and Employment Land Need . We consider this useful evidence, although we note that it comes without detailed site information as a SHELAA would include. This should be further refined, and inform a SHELAA, for the next iteration of the plan. The UCS does suggest further elements of supply that should be included in the next iteration of the plan. This includes some modest increase in density and inclusion of previous over-supply. However, most significantly the evidence presented in the Urban Capacity Study supports higher and more realistic assumptions about annual windfall housing. It shows that the windfall allowance in the Plan should be a figure somewhere between 450 and 901 dwellings per annum (dpa), that is to say, somewhere above half the historic annual rate over the decade 2011-2021, which has been 901 completions each year . This is supported by practical evidence on reductions in office requirements (a reduction of 30% in B1 use class floorspace across Warwickshire and Coventry, included in the HEDNA) and by well-known trends in future retail floorspace requirements, which are declining or at best have little market for expansion. This would be consistent both with the evidence of actual windfall supply (as opposed to plan figures) in Warwick and Stratford Districts and with the NPPF definition of windfalls, which does not limit the size of windfalls, but relies only on ‘compelling evidence’ as set out in Para 71. We note that the proposed figure of 4840 houses provided by windfalls, which is 220 dpa from 2028 to 2050, is not even the correct figure for small windfalls which would be 242 dpa. And projections of windfalls should start from 2025, not 2028, allowing 3 years from the date of the calculation. This alone would provide 6050 new houses dwellings (up to the Plan end date of 2050) from small windfall sites alone. Only when a more up-to-date calculation is made would it be appropriate to advance the start date for future windfall estimates, as early windfalls became actual permissions. The impact of increasing the Windfall allowance is set out in tabulated form in the report submitted by CPRE, based on the housing requirement included in the Plan (for end-years of the Plan of 2040; 2045; and 2050 as alternatives). below, based on the housing assumption in the Plan. It can be seen that the level of shortfall would significantly reduce, protecting the countryside and Green Belt from unnecessary encroachment. (PLEASE NOTE - the formatting of this on-line response does not permit presentation of these tables here) There is also consideration of additional supply by redeveloping or building over car parks in the urban areas. The UCS suggests a range of between 800 additional residential units (low) and 3400 (high) is feasible, depending on how many car parks are replaced by residential development or have development built over them. This would require further work but could be significant. The Councils should commission a more detailed study on whether car parks could or should be used to accommodate additional housing before the next iteration of the plan.

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 over greenfield sites. These non-greenbelt brownfield sites 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 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.

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 over greenfield sites. These non-greenbelt brownfield sites 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 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.

Brownfield sites need to be prioritised and where this is not possible, development does not occur in Greenbelt land. I do not feel 'call for sites' approach sufficiently prioritises the identification of non greenbelt brownfield site or greenfield sites, and that these need to be actively sought. The consultation document is heavily bias towards development of greenbelt to the North of Leamington Spa and this should be avoided, especially when 1/3 of the plan area is greenbelt. I feel appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances" (and whom deems what is 'exceptional, this is objective?!) Greenbelt must be avoided.

The production of an Urban Capacity Study (UCS, October 2022) to support identification of brownfield land to help deliver the growth needs of South Warwickshire is in accordance with the NPPF. The following points are made in relation to how the UCS considers housing supply in the urban areas. However, it should be noted that the UCS also discusses the SWLP housing requirement and representations are made on those points under Q-H1-1 & 2. In relation to housing allocations from the adopted Local Plans, HLM consider that a comprehensive review of all outstanding allocations without planning permission is required to ensure that such sites still meet the definition of developable as set out in the NPPF. In particular, evidence will be required to demonstrate why the UCS suggests the capacity of some of the allocations will increase beyond what is included within the adopted Local Plan, in particular as development proposals will need to show at least a 10% Biodiversity Net Gain from November 2023. That review and evidence must be published prior to the next iteration of the Plan to demonstrate the capacity from the allocations can be relied upon to meet the housing need. The UCS also includes within the supply 795 dwellings on sites which have been submitted to the SWLP Call for Sites process in the urban areas, and are considered to be potentially suitable. As no formal assessment of these submissions has taken place, their inclusion will need to be reviewed once the Housing and Economic Land Availability Assessment (HELAA) is published. Any allowance for such sites must be deducted from the windfall allowance. The UCS identifies an additional five sites on vacant land in the urban areas which have not yet been submitted to the Call for Sites process, but are considered potentially suitable for 328 dwellings. There is no certainty around the availability and deliverability of these sites to include them at this stage. Further, on assessment of these sites there are some serious concerns around their suitability in any case. The UCS also identifies two additional sites on brownfield land within the urban areas, at Talisman Square, Kenilworth (65 dwellings) and Westgate House, Warwick (39 dwellings). As above, these sites have not yet been submitted to the Call for Sites process and so there is no certainty around delivery. Finally, the UCS includes an assessment of the potential windfall supply with reference to the level of windfall delivery across South Warwickshire in the period 2011/12 to 2020/21. However, it is considered that this assessment is limited as it does not detail the sources of windfall supply, nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence as required by the NPPF.

The Brownfield Pledge is not referenced in the study. The proposed use of Greenbelt land should not be automatically included, just because the housing numbers cannot easily be found on other land classifications.

When redeveloping brownfield land for housing it is essential that infrastructure is improved to ensure that sufficient capacity will be available to meet the increase in households. It is also necessary to create green space and green corridors across brownfield land developments, nobody wants to see concrete jungles created, or high density housing typical of Dicken Heath (Solihull) in our rural county, much better to have lower density and space to breath.

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

The Government has also made a “brownfield first” pledge which should inform the way that the District Councils respond to unmet housing need in other authorities. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit.