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

The limitations of the Urban Capacity Study (Arup 2022) are highlighted in the report. The study is a theoretical exercise only. It is not intended to conclusively establish the urban housing capacity of South Warwickshire over the period to 2050. Instead it simply indicates a current potential urban housing capacity. More detailed work is required to confirm actual capacity. It is important to note that the study has not been informed by the outcome of an area-wide HELAA. The Urban Capacity Study concludes that there is a potential 19,950 housing supply (including windfall sites) and states that there is an additional potential up to 3,400 dwellings capacity that could be delivered on car parks. This means that in total up to 23,350 dwellings may be able to be delivered in urban areas in South Warwickshire. This assumes that all sites identified in the urban capacity study are deliverable and viable, and that the upper number of dwellings to be delivered on car parks is achievable. All of these assumptions require further testing, including on a viability basis, once the HELAA has been published. This identified capacity compares to a total baseline housing need in the area of 41,975 dwellings as calculated from the trend based calculation in the HEDNA, assuming a plan period from 2025-2050. This results in a c.18,625 dwelling shortfall (which could be higher once any cross-boundary apportionment of development from Coventry and / or Birmingham has been taken into consideration). The study concludes that it is unlikely to be possible to meet current development needs without significant greenfield development. However, in light of the figures set out above, the study should categorically conclude that a significant amount of greenfield development in sustainable locations will be required.

We note the discussions about utilising public car parks as potential housing sites. We note that the Arup Urban Capacity study identifies a potential housing supply of around 14,750 dwellings plus windfall 4840 and highlights a need for South Warwickshire over the plan period to be about 30,750 and concludes it is unlikely to be possible to meet current development needs without greenfield development. It is not absolutely clear to the lay person if these figures include the unmet housing need from elsewhere.. We do not have the technical expertise to comment on the Urban Capacity Study but would like to be fully involved in discussions about specific sites further down the line.

QS3.2 Option S3. 2b. Prioritise brownfield sites inc. existing buildings where possible. I feel it is very important to have settlement boundaries.

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 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 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.

e 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 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.

Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

The use of Brownfield sites should be the priority and if Brownfield cannot be used then the Green belt should definitely not be used. The consultation document is heavily biased towards development in the greenbelt of North Leamington, the should not happen, especially as only 1/3 of the plan area is greenbelt. Greenbelt must be avoided as an absolute priority.

Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

Issue S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

Issue S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

Q-S3.1 - 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.

Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

Q-S3.1 - 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.

2.26. The Urban Capacity Study identifies a potential baseline housing supply for the 2025-2050 plan period of 19,950 dwellings. Of this, 6,145 dwellings would be located within existing urban areas and the remainder located elsewhere (including new settlements). 2.27. The conclusion drawn at Section 4.6 of the Urban Capacity Study confirms that greenfield land must be released to meet South Warwickshire’s housing needs and states that: “However, 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.” (Section 4.6, Page 37, own emphasis) 2.28. While the study indicates that the shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire, this would seem highly unlikely given the significant programme of intervention and management that would be required for such capacity to be realised. The Respondent would also anticipate the likely yield from such sites to be considerably less than 3,400 dwellings and more likely towards the lower end of the range indicated (800 dwellings). 2.29. In the Respondent’s view, the inevitably of significant greenfield land being required adds considerably to the case for Green Belt release given that it is within the Green Belt that development can be most sustainably located. 2.30. It is agreed that to allow choice and competition in the market in accordance with National Planning Practice Guidance (NPPG) a buffer should be applied to the housing need as suggested in the UCS (UCS, Paragraph 4.6). The Local Plans Expert Group (LPEG) recommends a 20% buffer.

Issue S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

Issue S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

Q-S3.1 - 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 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.

Issue S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

I feel that the use of brownfield sites should be prioritised and that, where brownfield development is not possible, 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.

Q-S3.1 - Urban Capacity Study: I feel that the use of Brownfield sites and other sites should be prioritsed 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. The non-mitigatable and undoable damage from such developments on greenbelt are unforgivable from an ecological and climatical viewpoint.

Before brownfield land is classed as being ‘suitable’ for development,10 an ecological assessment should be undertaken to identify the ecological value of the site. In particular, consideration should be given to whether the site constitutes the priority habitat of ‘open mosaic habitat on previously development land’. If this is the case, then the land should not be developed unless it can be demonstrated that the development would not harm this priority habitat. 10 https://cdn.buglife.org.uk/2020/01/Identifying-open-mosaic-habitat.pdf

Q-S3.1 - 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 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”.

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.

Q-S3.1 - 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 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.

Q-S3.1 - 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. We 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. We 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.