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

We feel that it is wrong to develop green belt for (possibly executive style) housing, when it is not as easy to accommodate for numbers elsewhere. The government pledge for 'brownfield first' should be honoured, especially when trying to provide affordable housing in towns and cities.

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.

Before using green belt, you need to provide quantitative details of available brownfield and in particular, higher density (flats) within town centres as opposed to suburban sprawl. How much of the actual, identified needed new housing could actually be accommodated by within town and brownfield?

There does not seem to be mention of the 'brownfield first' pledge supported by national government, instead there is an assumption the greenfield sites within the greenbelt should be used in preference. Development in greenbelt areas is likely to encourage low cost, high profit developments aimed at executive style homes rather than lower cost housing near to employment centres. Of course, landowners and developers would be very happy to submit land for development in this scenario, but it will not support local infrastructure improvements to sewage, power, active transport and the like which the SA notes are sorely needed (sewage, water and power nearing or being at capacity). This is why the brownfield first pledge is so important and should not be ignored on a base assumption put forward by those who stand to profit from greenfield development the most.

In addition; 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.

The Brownfield first pledge is not referenced in the study or the main consultation. It should be more explicitly referenced. There should also be a recognition that green belt land does not have to be released simply because the numbers are not easily accommodated elsewhere.

If the brownfield sites are close to shops and businesses, then it's a win-win. If they're detached from a town (disused airport, etc) , then the gain doesn't seem to be great.

The Government have made a "brownfield first" pledge and this should be followed. It is sad to see unused commercial premises going to waste and good quality green field land being used for building to the detriment of wildlife and people's quality of life. Every opportunity should be taken to use brownfield sites. These also generally have better transport connections.

Sometimes there could be greater benefits environmentally from regreening brownfield sites than from building on low-grade greenfield sites. There could also be big societal gains from introducing more green areas into already heavily developed areas. Brownfield sites should not therefore always be chosen for development over some greenfield sites

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.

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.

Regeneration of existing urban sites is an obvious priority. It protects Green Belt.

RECOMMEND SHOULD USE BROWNFIELD LAND WHERE POSSIBLE

Support brownfield first

Infil should be prioritised to the development of 1/2 bedroom apartments, as generally larger developments do not always allocate enough to small units. Those residents who need to live within the more central location of a town, may be more likely not be in a position to have their own transport or have mobility issues, but will rely on walking,cycling or local transport to move around the town. Where a town or large village has only the one car park, then this should not be considered, even with the suggestion of building a multistorey car park within the infil. Not only would this have the possibility of killing the trade within that locality, but it would also be expensive and may not be very pleasant to 'live with'.

The Issues and Options Consultation does not offer a specific opportunity to comment on issues around brownfield land. However, the Urban Capacity Study speaks to this issue and is considered in the section of the Issues and Options relating to the use of brownfield land and so these comments (which relate to brownfield development rather than the Urban Capacity Study per se) are presented here. The Issues and Options should promote a strategy which encourages the development of brownfield land. However, it is important that the focus is not too narrowly placed on brownfield sites. One of the most significant opportunities presented by the joint approach between the two Authorities is the ability to realise the potential offered by the M40 as a strategic route bisecting the Plan area and linking Birmingham and London. This has been under utilised to date but should now be embraced as an asset enabling growth with strong economic and social credentials that can also be carried out in an environmentally sensitive manner. The character of the M40 corridor is such that this will inevitably require greenfield development but that should be supported as part of a balanced approach to sustainable growth alongside making the most of brownfield opportunities. One such opportunity to realise the potential of the M40 corridor is land north west of Junction 15 which was promoted through the Call for Sites (response form and site location drawing reference 6484-16 were submitted). As indicated on the interactive map it was given the reference number 44 by the Councils and extends to about 60ha. It is extremely well suited to meeting the strategic industrial and logistics requirement in this part of the Plan area. On a related matter, the Issues and Options Consultation similarly does not offer a specific opportunity to comment on issues connected with the Green Belt. This is understandable in circumstances where the technical work around Green Belt review has not yet been undertaken, and so the Issues and Options are blind to this matter. The Issues and Options give a clear indication that such work will be undertaken, and this is essential. It is of particular relevance to the opportunity offered for development in the M40 corridor, which passes through the Green Belt. The Exceptional Circumstances required to remove land from the Green Belt are capable of being demonstrated by the need to meet development requirements, and the requirement for large scale industrial and logistics development in locations well related to the M40 and its junctions invites careful consideration of where such changes to the Green Belt might best be made. It is considered that the technical work around considering Green Belt release should be pursued as a priority, with the opportunity provided first for consultation on its scope and method, and later for comment on its findings.

I feel strongly that brownfield sites should be prioritised, where this is not possible then development should NOT occur in Greenbelt land. A 'call for sites' is not sufficiently prioritising the identification of non greenbelt brownfield sites or greenfield sites, these should get priority and be actively sought out. I feel the consultation document is heavily biased towards development in the green belt North of Leamington and this should be avoided. Greenbelt development MUST be avoided as an absolute priority.

Green belt land should be maintained so as to protect the enjoyment of the countryside for all. Potential for brownfield development should therefore be of primary importance to regenerate this land, take away redundant sites, support local economies, shops and restaurants and other businesses. Once greenbelt land is used it is lost for ever and changes the character of not only the immediate vicinity but the wider area

The urban capacity study consists of a 200-page document, which is separate to the main consultation. The "Brownfield first" approach is not referenced in the main consultation or the study, and it should be more explicitly referenced to note that Green Belt does not need to be released purely because numbers are not found easily accomadated somewhere else.

I do not not think that the "call for sites" approach does enough to prioritise brownfield sites which should be the preferred option over Greenbelt land development and this should be the case. If necessary greenfield sites NOT in designated Greenbelt land should be the next option. The plan in the consultation document is biased towards development of greenbelt land North of Leamington and this should be avoided. Greenbelt development should be avoided and this should be a top priority in the plan.

The use of brown field land in urban areas should be a priority to reduce development on green field site.

There are significant areas of brownfield land which should be developed to provide more affordable houses within the areas where people can work. This will ultimately benefit the local area by providing more affordable houses without the need to deliver extra infrastructure (rail roads and busses) and by not destroying the countryside with more developments that can only realistically be accessed by car drivers. Development of our towns should be the priority rather than joining up our villages with development, this is the only option that delivers a sustainable future.

Whilst the intelligent regeneration of brownfield land must form part of any forward-looking land use plan, care is required to ensure that brownfield land does not become an inappropriate reference point to prevent sustainable development from coming forward. The idea of “intensification” areas of development outlined in S2 is an example of where a lack of clarity can result in poor planning outcomes. Waves of urban intensification have seen major decline in living conditions – including through reduced privacy, increased overlooking, harm to outlook, increased noise and disturbance, increased congestion, reduced greenery, a loss of heritage, open space, harm to attractive uniformity – an almost endless list, whereby previously beautiful urban areas have been inappropriately intensified, to the harm of occupiers. Building houses in gardens and cramming flats into tight sites does not result in the best planning outcomes. At the same time, there are swathes of land of little biodiversity quality that could provide for beautiful development. Unfortunately, the clamour from existing communities to “protect green fields” often leads to poor planning outcomes that despoil urban areas under the guise of protecting something that doesn’t exist (some kind of emotive “green paradise”). This approach inevitably leads to planning by appeal, resulting in the development of lowest common denominator of speculative unplanned estates of housing that – because they are unplanned - fail to bring with them necessary infrastructure etc. Plan-making needs to look forward, not backwards. This requires making good use of appropriate brownfield land, but more importantly, it requires the boldness of vision to plan for genuinely sustainable development. It would be refreshing to see a SWLP that actively plans for the future by balancing sensitive green field release for sustainable development alongside appropriate brownfield development.

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 summary, the housing requirement is substantial and William Davis would agree with the following statement in the UCS: “we consider it impossible to meet development needs without significant greenfield development”. In relation to housing allocations from the adopted Local Plans, William Davis 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. 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.

Brownfield sites are infinitely more suitable for development than those in the greenbelt. While the draft plan refers to support at the initial stage for greenbelt development, the level of responses is so low that it should not be relied upon. In addition, responses are likely to have come to a large extent from those with interests in greenbelt land, who will benefit financially from devleopment of this land. I would refer again to the NPPF and the requirement for exceptional circumstances for greenbelt development and given the options for brownfield land and areas outside the greenbelt this cannot be considered as met

The examples given in the study are encouraging and a wider-ranging, more detailed exercise should be undertaken to ensure that the “brownfield first” pledge is met. The need to prioritise brownfield development comes across clearly in recent Government policy. The “brownfield first” pledge was most recently reiterated by the Prime Minister in answer to a Parliamentary Question on 6.10.22. Most brownfield sites are sustainable because they are located in areas with train stations and bus routes. It may be necessary to explore meeting the costs of remedial measures from public funds to make the use of these sites viable for developers. Additionally, we support the suggestion of the Secretary of State for LUHC (written statement 6.12.22) to explore setting a lower Infrastructure Levy rate on brownfield over greenfield to increase the potential for brownfield development. This would allow South Warwickshire to reflect national policy and deliver the “brownfield first” pledge by giving substantial weight to the value of using brownfield land. Certain types of intensification in town centres should be supported for example the conversion of unused retail property, including upper floors, to provide housing. In terms of the way that brownfield development is measured, it is important to be specific about the number of dwellings rather than the number of sites. For example, the current Warwick District Plan states that it seeks to maximise the use of brownfield sites with 9% of allocated sites using brownfield land. It does not say what percentage of houses would be on brownfield sites, which might not be very different depending on the size of the brownfield as opposed to greenfield sites.

Paragraph 141 of the NPPF as adopted and in the current consultation version both seek to prioritise the use of brownfield land before looking to take land out of the greenbelt. However as identified in the Issues and Options Consultation document, some brownfield sites are located away form settlements such as airfields and by virtue of their location would not be classed as sustainable. However, the Council’s own growth strategy requires the development of brand-new settlements which will have to be in locations outside of the built-up boundaries of urban areas, in order to meet the required housing need. These new settlements will by virtue of their size will be able to provide the funding for their own infrastructure and therefore become sustainable. This may also be the case for smaller developments which seeks to extend existing village settlement boundaries, and therefore increasing the critical mass required to have more services and infrastructure. Not all brownfield development is acceptable; whilst most brownfield sites are located within the urban environment, the urban capacity study has discounted some of these small sites as being unsuitable. Smaller sites also have physical constraints from the existing built environment which means that their development can negatively impact on the amenity of existing residential development as well as negatively impacting on the operation of commercial uses. The urban capacity study has looked at the possible redevelopment of a number of large car parking in town centres to provide some of the housing numbers. The study itself acknowledges that in order for this to happen there would need to be significant interventions and management; this is a strategy which is unprecedented in South Warwickshire and nationally. Regardless of this, it is impossible to provide the housing numbers required over the plan period unless none brownfield development is undertaken. Brownfield development may also with higher development costs where additional care needs to be taken with regards to contamination, impact on access and additional amenity mitigation to make development acceptable. Greenfield or non-brownfield development whilst having to provide brand new infrastructure, has a better opportunity to provide other benefits such as open space, larger plot sizes and affordable housing to help existing settlements.

I wholly support the use of brownfield land for development. Including wherever possible the renovation of flats that sit empty above shops and other town centre locations. VAT rules should be amended to encourage the renovation and improvement of existing buildings and to discourage developers from always prefering green field sites!

The study should also consider the implications on existing infrastructure, including health, education and transport. More consideration should be given to Open Green Space, sports and recreation and site housing densities that allow for these.

Paragraph 141 of the NPPF as adopted and in the current consultation version both seek to prioritise the use of brownfield land before looking to take land out of the greenbelt. However as identified in the Issues and Options Consultation document, some brownfield sites are located away form settlements such as airfields and by virtue of their location would not be classed as sustainable. However, the Council’s own growth strategy requires the development of brand-new settlements which will have to be in locations outside of the built up boundaries of urban areas, in order to meet the required housing need. These new settlements will by virtue of their size will be able to provide the funding for their own infrastructure and therefore become sustainable. This may also be the case for smaller developments which seeks to extend existing village settlement boundaries, and therefore increasing the critical mass required to have more services and infrastructure. Not all brownfield development is acceptable; whilst most brownfield sites are located within the urban environment, the urban capacity study has discounted some of these small sites as being unsuitable. Smaller sites also have physical constraints from the existing built environment which means that their development can negatively impact on the amenity of existing residential development as well as negatively impacting on the operation of commercial uses. The urban capacity study has looked at the possible redevelopment of a number of large car parking in town centres to provide some of the housing numbers. The study itself acknowledges that in order for this to happen there would need to be significant interventions and management; this is a strategy which is unprecedented in South Warwickshire and nationally. Regardless of this, it is impossible to provide the housing numbers required over the plan period unless none brownfield development is undertaken. Brownfield development may also with higher development costs where additional care needs to be taken with regards to contamination, impact on access and additional amenity mitigation to make development acceptable. Greenfield or non-brownfield development whilst having to provide brand new infrastructure, has a better opportunity to provide other benefits such as open space larger plot sizes and affordable housing.