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

None.

The Urban Capacity Study considers the theoretical generation of housing land resulting from a number of urban sources, including town centres and employment areas, promoted brownfield sites, Council owned car park sites, empty homes and windfall development. Taking account of a 5% non - implementation rate, only land for 6,145 urban dwellings have been identified from a potential baseline need of 30,750 dwellings. A significant shortfall has therefore been identified. Taking account of sites with existing planning permissions and existing Local Plan allocations across the two Authorities, this figure rises to 23,350 dwellings. The Urban Capacity Study has considered all options for urban brownfield development / intensification. There remains a shortfall of 7,400 dwellings which will need to be provided elsewhere on greenfield sites within the Plan area. This therefore demonstrates a clear need for additional greenfield sites to come forward to meet the housing needs of the Plan area, notwithstanding that which may be required from adjacent Housing Market Areas.

The Urban Capacity Study considers the theoretical generation of housing land resulting from a number of urban sources, including town centres and employment areas, promoted brownfield sites, Council owned car park sites, empty homes and windfall development. Taking account of a 5% nonimplementation rate, only land for 6,145 urban dwellings have been identified from a potential baseline need of 30,750 dwellings. A significant shortfall has therefore been identified. Taking account of sites with existing planning permissions and existing Local Plan allocations across the two Authorities, this figure rises to 23,350 dwellings. The Urban Capacity Study has considered all options for urban brownfield development / intensification. There remains a shortfall of 7 ,400 dwellings which will need to be provided elsewhere on greenfield sites within the Plan area. This therefore demonstrates a clear need for additional greenfield sites to come forward to meet the housing needs of the Plan area, notwithstanding that which may be required from adjacent Housing Market Areas.

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. The land at Chessetts Wood Road, while currently used as a paddock previously developed land as a brickworks.

Q-S3.1 - 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.

Q-S3.1 - 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.

S3 – Brownfield development The urban capacity study identifies relatively little room for growth in the number of residential properties in existing urban areas. Neverthless 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. 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.

Urban Capacity Study 19. The Urban Capacity Study (UCS) considers the issue of windfall, concluding that evidence justifies a windfall allowance of 220 dwellings per annum across South Warwickshire, which it suggests can be applied from 2028-2050. This would equate to an overall total of 4840 dwellings. Of this total, it is estimated that 3360 dwellings would be within the 23 urban settlements of South Warwickshire. The HBF questions the robustness of this approach to windfall. 20. The HBF agrees with the observation (on page 30 of the UCS) that it is simply adopting historic windfall trends as an indicator of likely future rates of windfall is unlikely to be robust. The HBF also agree that a windfall allowance should not be included until the fourth year of a housing trajectory, given the likelihood that dwellings being completed within the next three years will already be known about (as they are likely to need to have already received planning permission to be completed within that timeframe). The Plan’s windfall allowance will need to be kept under review as the Plan progresses to ensure that it is informed by the latest data. 21. As set out in the NPPF (para 69a) at least 10% of the housing requirement should be accommodated on sites no larger than one hectare or demonstrate strong reasons for not achieving this target. The Council should ensure that the Local Plan is consistent with the NPPF. The Plan should allocate sustainably located small sites to help provide certainty for SMEs. This should be in addition to any windfall allowance. The Need for Small Sites 22. The HBF has undertaken extensive consultation with its small developer members. One of the chief obstacles for small developers is that funding is extremely difficult to secure without a full, detailed, and implementable planning permission. Securing an implementable planning permission is extremely difficult if small sites are not allocated. Without implementable consents lenders are uneasy about making finance available or the repayment fees and interest rates they set will be very high. Small developers, consequently, need to invest a lot of money and time up-front in the risky business of trying to secure an allocation and a planning permission, and this is money that many small developers do not have. 23. If the Councils are to ensure there is a wide variety of SME house builders operating in their administrative areas, and the benefits it brings to the speed of delivery and variety of homes, they must ensure that there is a variety of sites. This is why the Government, through the NPPF, now requires local authorities to allocate sites of varying sizes and why the HBF advocates for the allocation of more small sites in local plans. 24. It also will be important for the Plan’s policies and evidence base to set out how the plan will deliver 10% of homes on sites of less than one hectare, as required by paragraph 69 of the NPPF. The HBF would advocate that a higher percentage of small sites are allocated if possible. Such sites are important for encouraging the growth in SME housebuilders who will tend to develop these sites but rarely see the benefits that arise from the allocation of sites in a local plan. Up until the 1980s, small developers once accounted for the construction of half of all homes built in this country resulting in greater variety of product, more competition, and faster build-out rates. Since then, the number of small companies has fallen by 80%.

Q-S3.1 - 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.

Q-S3.1 - 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.

Brownfield sites should only be developed when it can be proven that the development is in a sustainable location or would increase the sustainability of the area. • Making sure that the development is in the local interest. • Determining if there is a more suitable location in line with the development strategy. • Determining if the development would be an improvement on the current use. • Determining the scale and nature of the impacts the development will have on the local community. • Ability to support sustainable travel. • Determining any potential areas of flood risk. • Appropriate existing infrastructure or a plan to develop same.

So much high grade farmland around South Warwickshire has been lost to low grade housing, it is important that your future plans to 2050 focus on BROWNFIELD FIRST. Your assessment of likely windfall (brownfield) land in the SWLP is seriously flawed. You assume 220 DPA. This is less than one quarter of the average windfall land coming available every year since 2011 – which is 901 DPA. Please reconsider this calculation.

Use of brownfield sites should be prioritised; green belt development should only be allowed where there is no other alternative. Have brownfield sites been proactively sought? Why does the urban capacity study appear to be biased to developing green belt land north of Leamington? This will go to the issue as to whether exceptional circumstances apply to green belt development (anywhere but particularly on the site between Weston and Hunningham) and in particular whether the WDC is able to demonstrate that it has “examined all the other reasonable options for meetings its identified need for development, including making use of brownfield land, increasing the density of existing settlements…” (NPPF).

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.

Q-S3.1 - Urban Capacity Study: Brownfield sites should be prioritised and where brownfield development is not possible, then development on greenbelt should not take its place. The "Call for Sites" approach does not priorities the identification of the type of site being proposed, all sites should be clearly identified as the category they fall into. avoiding greenbelt development must be the first 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.

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.

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.

Q-S3.1 - Urban Capacity Study: The use of Brownfield sites should be prioritsed and that where Brownfield development is not possible, then development should not occur in Green Belt land. In particular, I do not feel that the “call for sites” approach sufficiently prioritises the identification of non Green Belt brownfield or greenfield sites, these should be actively sought out. The consultation document is heavily biased towards development in the Green Belt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is Green Belt. I feel that appropriately planned development from the outset will avoid the need for Green Belt development in “exceptional circumstances”. The Planners assumption that Green Belt development will somehow be justified at a later date is a failure in lessons learned from the last Local Plan and must be avoided as an absolute priority.

Q-S3.1 - Urban Capacity Study: I 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, 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.

Brownfield sites must always be developed before using greenfield and greenbelt land. If some brownfield sites cannot be developed appropriately then they should be transformed into green spaces.

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). 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: “….. 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) 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). 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. 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 Urban Capacity Study (Paragraph 4.6).

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

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 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 Southam . • 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 REPORT JBB8799.C8269 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 5 • 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. 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 identified one previouslydeveloped site with an estimated capacity of 18 dwellings within Southam (Site ref. 512 – Land at Oxford Street) however the site is currently in retail use and therefore not available for development. No other potential development unconsented or unallocated sites have been identified within the settlement boundary. Consequently, it is inevitable that additional growth at Southam 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 Southam, 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).

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. • 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 REPORT | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 7 • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • It is 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 conducted. 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 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, 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).

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. • 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 REPORT | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 7 • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • It is 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 conducted. 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 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, 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, 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.