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.

2.4.1 The Urban Capacity Study (Arup, October 2022) includes consideration of windfalls as a source of supply for housing across the plan area. The proposed windfall allowance is based on historic trends and suggests that 4,480 dwellings could come forward between 2028 and 2050. Additional information is required to ensure that assumptions associated with windfall rates are robust. 2.4.2 Paragraph 71 of the NPPF notes: “Where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends.” 2.4.3 It is considered that in order to comply with Paragraph 71 of the NPPF authorities must provide additional evidence in relation to the sources of supply that windfalls will come from over the plan period, trend data may not be appropriate if historic sources of supply are coming to an end. This observation is consistent with the recommendation from Arup’s review of SHLAAs undertaken in 2019 in Greater Nottingham. The review highlighted the NPPF’s emphasis on both past evidence and future trends, and to allow a more nuanced and robust allowance it was suggested this could be carried out on a use class basis.1 2.4.4 It is also noted that Arup, in undertaking an analysis of windfall rates for the SWLP, recommended a review of windfall assumptions through the HELAA process (page 31 of the Urban Capacity Study). The windfall assumptions provided in the Urban Capacity Study should therefore be treated with caution until additional work on future trends associated with anticipated source of supply is undertaken. 2.4.5 The Urban Capacity Study considers the potential for additional housing development within existing settlement boundaries. The majority of identified capacity is associated with sites with planning permission that are not yet fully built out (5,878 dwellings) and allocated sites without planning permission (7,655 dwellings). 2.4.6 The Urban Capacity Study helpful in illustrating that urban capacity in the settlements reviewed is limited, some of the potential sources of supply that are identified (including existing town centre car parks) and employment sites serve an important role in helping to maintain the vitality and viability of centres and local employment and may not therefore be suitable for development and the study concludes that only two sites with potential capacity for 104 dwellings should be considered (if found to be suitable, available and achievable in the forthcoming HELAA). The study rightly emphasises the need for greenfield allocations in appropriate locations. 2.4.7 The Arup study demonstrates that there is limited potential for new sites to come forward within the boundaries of the settlements considered. This reflects not only the limited supply of brownfield land that is available, but also the inherent development constraints that are associated with many of these historic settlements due to their intrinsic character and sensitivity to change. Policies which encourage intensification are not therefore considered to offer a realistic avenue to meet any significant share of future development needs (S2c). 2.4.8 Brownfield development should be encouraged where it contributes to a sustainable pattern of development and is consistent with other objectives of the Local Plan, e.g. relating to the protection of employment land. The agent of change principle will also be important and could be reflected in any policy (S3.2a). 1 https://www.gnplan.org.uk/media/3371770/review-of-greater-nottingham-shlaas.pdf

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.

Many neighbouring authorities follow the policy of prioritising building on Brownfield land. The approach followed by the South Warwickshire Local Plan does not seem to favour Brownfield development, instead treating the green belt as equivalent and of no value to the Villages in this area.

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.

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.

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 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.

An Urban Capacity Study for South Warwickshire, dated October 2022, has recently been undertaken to inform the Local Plan. Its purpose is to identify the potential for residential development on brownfield land within the settlements in South Warwickshire. As pointed out in section 1.1 of the study report, a review of housing capacity has been undertaken in order to minimise the amount of development outside of existing urban areas. 3.7 The IO document goes on to state that the study has been undertaken as a theoretical exercise and is not intended to conclusively establish the urban capacity of South Warwickshire over the period to 2050, but rather to indicate potential untapped urban capacity within these identified settlements, subject to the application of policy and the conclusions of more detailed subsequent evidence work. That said, there are some important conclusions in the study that need to be emphasised at this stage as the study will form part of the evidence to underpin the development strategy in the SWLP. 3.8 The study has applied a number of important assumptions, as listed here: • The base date for the study and the conclusions around potential urban housing capacity is 1 st April 2021 • The study assumes that all of the sites considered will be developed as ‘conventional’ dwellinghouses in Use Class C3 (not specialist housing i.e. student accommodation or older persons housing). • Capacity was measured on sites located in 23 settlements across the SW area, including Main Rural Centres defined in the Stratford-upon-Avon Core Strategy, and Growth Villages as defined in the Warwick Local Plan. This includes sites located in Shipston-on-Stour. • The Urban Capacity Study does not represent a HELAA-level consideration of suitability, availability and achievability, it is important to note that it will be for the forthcoming HELAA to establish whether these sites are actually deliverable or developable in practice. 3.9 Section 4.6 of the study provides a summary of the overall potential urban housing capacity across South Warwickshire: • Total housing assumed over SW area for the 2025-2050 plan period is 30,750 dwellings, using the baseline figures based on the standard method • Total potential baseline housing supply for this period is 19,950 dwellings • Only 6,145 (31%) dwellings would be located within existing urban areas, the rest is located elsewhere • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • Suggested there is some potential to increase densities on some sites • Potential yield of 3,400 dwellings by redeveloping public car parks, but this would necessitate a significant programme of intervention and management in order to be realised. 3.10 The study therefore identifies a significant shortfall in the potential for new housing to be accommodated on previously-developed land. The shortfall is currently 10,800 dwellings. This should be taken as a minimum shortfall, as not all sites with potential will actually be deliverable or developable once a full assessment has been carried out. 3.11 Based on these findings, the study concludes 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.” (RPS emphasis) 3.12 Furthermore, the shortfall is set against the standard method housing need figures (1,230 dpa across the whole area over 25 years). However, the IO document advocates for the use of an alternative ‘trend-based need for South Warwickshire, which gives a need for 1,679 dpa. Against this figure, the total need between 2025-2050 increases to 41,975 dwellings, thus increasing the shortfall to 22,025 dwellings. This clearly demonstrates that the focusing policy objectives on previously-developed land will not deliver anywhere close to the projected needs of the SW area, and therefore planning for development on greenfield land in sustainable locations must form part of development strategy for the SWLP. 3.13 In addition, under the assessment of sites by settlement, the study did not identify any sites at Shipston-on-Stour with development potential within the settlement boundary. It is inevitable that additional growth at Shipston-on-Stour will need to be allocated on the edge of the settlement. 3.14 The IO document presents three options under this issue. On the basis of the current evidence provided on housing capacity, RPS would recommend that development on previously-developed land is supported only where sites are shown to be viable and deliverable, as well as being sustainably located. However, given the paucity of the overall supply from sites within urban areas, notably at Shipston-on-Stour, it is not considered reasonable to prioritise brownfield development ahead of other, greenfield locations as a matter of principle as this would put at grave risk the ability of the SWLP to meet the identified needs of the area. On this basis, RPS would not support Option S3.2a or S3.2b (and thus supports Option S3.2c)

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.

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. Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Brownfield site should be given the upmost priority and areas should only be proven to be an unsustainable location if regeneration projects of the area to make it a sustainable option is not viable.

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.

Develop Brownfield only for the first 5 -10 years and then reassess. There are 806 Ha of brownfield in the HMA, on the latest published registers, enough for 27,000 new homes. As policy, there should be a presumption that in that moratorium period, green field sites will be refused unless it can be shown there is no alternative in the local authority [most of the brownfield is in Stratford and Coventry].

Develop Brownfield only for the first 5 -10 years and then reassess. There are 806 Ha of brownfield in the HMA, on the latest published registers, enough for 27,000 new homes. As policy, there should be a presumption that in that moratorium period, green field sites will be refused unless it can be shown there is no alternative in the local authority [most of the brownfield is in Stratford and Coventry].

The local plan must require Brownfield be developed first, before building on open green fields. According to the latest published brownfield registers, there are very substantial areas of brownfield currently available [806ha] , sufficient for 32,245 homes. Even if one accepts the HEDNA, which I do not, this would provide housebuilding land for 8-9 years of building in the Coventry and Warwickshire housing market area at 3,500 dwellings/year. As policy measure, no green field land should be allocated for development until a plan review, and any following plan r eview, determines that therre is an actual need for green field land, to service the realistic population growth of t he area – At the first 5 year review of the plan, we will be able to see the result of windfalls, and make an interim assessment of housing need on the basis of local evidence [births, deaths, school populations, electoral role, job creation, car registrations, NI registrations, gas and electric use, student migration, etc]. The There should be an explicit commitment to brownfield first in accord with the Secretary of State’s, letter of 5 Dec 2022 to MPs which announces a section entitled “Brownfield first”. Local authority date ha brownfield north warks mar2022 13.61 rugby mar2020 17.14 Coventry 2022 102.5376 Warwick 2022 72.05 Stratford 2019 600.784 806.1216 homes at 40/ha 32,245

4.6 An Urban Capacity Study for South Warwickshire, dated October 2022, has recently been undertaken to inform the Local Plan. Its purpose is to identify the potential for residential development on brownfield land within the settlements in South Warwickshire. As pointed out in section 1.1 of the study report, a review of housing capacity has been undertaken in order to minimise the amount of development outside of existing urban areas. 4.7 The IO document goes on to state that the study has been undertaken as a theoretical exercise and is not intended to conclusively establish the urban capacity of South Warwickshire over the period to 2050, but rather to indicate potential untapped urban capacity within these identified settlements, subject to the application of policy and the conclusions of more detailed subsequent evidence work. That said, there are some important conclusions in the study that need to be emphasised at this stage as the study will form part of the evidence to underpin the development strategy in the SWLP. 4.8 The study has applied a number of important assumptions, as listed here: • The base date for the study and the conclusions around potential urban housing capacity is 1st April 2021 • The study assumes that all of the sites considered will be developed as ‘conventional’ dwellinghouses in Use Class C3 (not specialist housing i.e. student accommodation or older persons housing). • Capacity was measured on sites located in 23 settlements across the SW area, including Main Rural Centres defined in the Stratford-upon-Avon Core Strategy, and Growth Villages as defined in the Warwick Local Plan. This includes sites located in Bidford-on-Avon. • The Urban Capacity Study does not represent a HELAA-level consideration of suitability, availability and achievability, it is important to note that it will be for the forthcoming HELAA to establish whether these sites are actually deliverable or developable in practice. 4.9 Section 4.6 of the study provides a summary of the overall potential urban housing capacity across South Warwickshire: • Total housing assumed over SW area for the 2025-2050 plan period is 30,750 dwellings, using the baseline figures based on the standard method • Total potential baseline housing supply for this period is 19,950 dwellings • Only 6,145 (31%) dwellings would be located within existing urban areas, the rest is located elsewhere • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • Suggested there some potential to increase densities on some sites • Potential yield of 3,400 dwellings by redeveloping public car parks, but this would necessitate a significant programme of intervention and management in order to be realised. 4.10 The study therefore identifies a significant shortfall in the potential for new housing to be accommodated on previously developed land. The shortfall is currently 10,800 dwellings. This should be taken as a minimum shortfall, as not all sites with potential will actually be deliverable or developable once a full assessment has been carried out. 4.11 Based on these findings, the study concludes 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.” 4.12 Furthermore, the shortfall is set against the standard method housing need figures (1,230 dpa across the whole area over 25 years). However, the IO document advocates for the use of an alternative ‘trend-based need for South Warwickshire, which gives a need for 1,679 dpa. Against this figure, the total need between 2025-2050 increases to 41,975 dwellings, thus increasing the shortfall to 22,025 dwellings. This clearly demonstrates that the focusing policy objectives on previously developed land will not deliver anywhere close to the projected needs of the SW area, and therefore planning for development on greenfield land in sustainable locations must form part of development strategy for the SWLP. 4.13 In addition, under the assessment of sites by settlement, the study identified one possible employment area in Bidford-on-Avon that merited consideration for housing development, namely Waterloo Industrial Estate / Bidavon Industrial Estate. However as set out in Table 9 on page 27 of the study it is noted that given high levels of occupancy, away from a small area currently being redeveloped for housing adjacent to Waterloo Road, potential for further residential development is limited. No other unconsented or unallocated potential development sites have been identified within the settlement boundary. Consequently, it is inevitable that additional growth at Bidford-on-Avon will need to be allocated on the edge of the settlement. 4.14 The suitability of the site for development has already been identified in the emerging Site Allocations Plan, which has identified the site as a reserve site, indicating that both further development at Bidford-on-Avon is appropriate and also that the site itself is suitable for development. 4.15 The IO document presents three options under this issue. On the basis of the current evidence provided on housing capacity, RPS would recommend that development on previously-developed land is supported only where sites are shown to be viable and deliverable, as well as being sustainably located. However, given the paucity of the overall supply from sites within urban areas, notably Bidford-on-Avon, it is not considered reasonable to prioritise brownfield development ahead of other, greenfield locations as a matter of principle as this would put at grave risk the ability of the SWLP to meet the identified needs of the area. On this basis, RPS would not support Option S3.2a or S3.2b (and thus supports Option S3.2c).

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.

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.

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.

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.

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.

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.

We have reviewed the Urban Capacity Study by Arup dated October 2022. Net of outstanding commitments and windfalls, it identifies an overall capacity of 1,231 dwellings. For the sake of comparison, the Housing and Economic Development Needs Assessment (HEDNA) identifies a base annual housing need in South Warwickshire of 1,432 dwellings per annum (dpa). As such, even if all of these sites were to come forward at the assumed densities, their contribution to meeting housing need would be minimal. Bellway also have concerns about the robustness of some of the sites identified as contributing towards urban capacity. For example, The Greens South of Alcester Road in Stratford-upon-Avon is assumed to have a capacity of some 80 units but was refused planning permission for 57 dwellings by the Council on heritage amongst other grounds. It is clear therefore that many of these sites may not proceed beyond the land availability assessment. Bellway recognise that the Urban Capacity Study may not have looked at rural brownfield sites although given the sustainability challenges associated with such sites, they will likely make a negligible contribution. Accordingly, the evidence base shows that whilst brownfield development could always be prioritised, it will only make an, at best, minimal contribution towards meeting housing need on the Councils’ own evidence.