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

I assume that this study has been made on the basis of the growth expected to happen in SW. No-one seems to have addressed the following issues: 1.why to we need growth in the SW economy? Growth per se should not be the objective-rather productivity should be the key objective although this is a much more difficult target. However achieving significant productivity improvements in SW is what will drive better standards of living for its inhabitants 2. what industries should we be supporting to generate growth if that is the desired objective?

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.

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

I support the use of brownfield sites for development. This avoids taking productive agricultural land out of use; is likely to be close to relevant infrastructure such as hospitals and schools; and carbon emissions from transport are likely to be reduced.

All new housing should that is not on brownfield sites should score highly for sustainability - medium/high density and served by major public transport infrastructure and cycleways.

The Urban Capacity Study, a 200 page document separate from the main consultation has been made in recognition of the "need to use urban land efficiently". The "Brown Field Pledge First" (see the letter from the Secretary of State for Levelling up, Housing and Communities) is not referenced in the Study or the main Consultation. The “brownfield first” pledge which should inform the way that the District Councils respond to unmet housing need in other authorities. Greenfield development of executive style homes is much more attractive to developers but this is in tension with the actual need for affordable housing in the towns and cities where most people work. The Government’s “brownfield first” pledge should be reflected in the duty to co-operate with other local authorities, ensuring that larger conurbations are not avoiding the need for creative brownfield solutions in the areas where people work and instead shunting their housing need out to other areas where developers can make a bigger profit.

Brownfield land should be developed first before other land

This proposal 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.

Brownfield sites should be developed as a priority with corresponding infrastructure even if this is more expensive.

Dependent on the results of the urban capacity study, it could be that brownfield development forms a part of our development strategy. Brownfield sites are frequently found within towns and can therefore often accommodate a higher development density. Prioritising development on brownfield land, especially at higher densities, might reduce the need for greenfield development. However, instead of developing all brownfield sites, this option looks to prioritise brownfield redevelopment in line with the identified growth strategy, where it can be proven the site is in a sustainable location, or when the development can show that it would have a positive impact on the sustainability of the area. In some instances

The production of an Urban Capacity Study (UCS, October 2022) to support identification of brownfield land to help deliver the growth needs of South Warwickshire is in accordance with the NPPF . The following points are made in relation to how the UCS considers housing supply in the urban areas. However, it should be noted that the UCS also discusses the SWLP housing requirement and representations are made on those points under Q-H1-1 & 2. In relation to housing allocations from the adopted Local Plans, Rosconn Strategic Land 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 .

fully agre that future development must take place on brownfield land as a priority

No answer given

This is of particular importance so that it is not necessary to build on any of the Green Belt.

Brownfield land development should be prioritised. The call for sites approach does not sufficiently support this. Brownfield sites should be specifically identified in an active approach. Greenbelt development should be avoided as an absolute priority or else it will run counter to an objectives around an environmentally sensitive approach and one that seeks to reduce GHG emissions.

Brownfield sites, and development/redevelopment of existing poorly kept areas should be only options. Building in countryside is damaging to environment, well being, and is inappropriate especially for affordable housing. Housing like this is better close to jobs and transport hubs. There are lots of derelict buildings and wasteland that is an eye sore and unproductive. It is unbelievable that these are just left, and the countryside built on. The plans for my village are horrendous - building planned right along road to next village.

We are concerned about the number of houses identified and their type. We believe there is a greater need for Social/Rented housing than Affordable Social housing and that market housing should be family sized and mainly 3 bedroom. There does need to be an emphasis on Lifelong Housing. This doe not appear to be a strategy in market housing although social rented accommodation on the same development includes it. We are concerned that the majority of sites identified are not within existing urban boundaries and strongly support that they should be and not encroach on the green spaces around urban developments. We support the use of brownfield sites but not those not included in Neighbourhood Plans, these should be used to inform decisions. Sites should be in line with neighbourhood Plans and within boundaries.

IMPORTANT WE USE BROWNFIELD SITES AND REVIEW GREEN BELT AREAS

Agree with the concept but would expect all brownfield to be used prior to any development on greenfield

Inconclusive. Vital information which has been mentioned but is not included. As stated "The Study does not consider the implications on existing infrastructure, for example education, health, transport." It needs to to be worthy of comment.

Comments relating to site 592. 1. How consistent are the criteria rankings with the Stratford on Avon SHLAA & Site Allocations Plan? Site 592 (STR.18 in SHLAA and Site Allocations Plan) was shown as Red ranking for Adjusted Overall Deliverability (with an undefined asterisk). Red is defined as Not Deliverable. Based on the acknowledged limited research for the Urban Capacity Study and also the fact that the Urban Capacity Study states that the HELAA will.....and follow a similar approach in considering the suitability, achievability and availability of land for housing" it seems illogical for this site to have become "potentially suitable" rather than not considered suitable. 2. The Urban Capacity Study shows site 592 as Land Type "Brownfield". I believe this is incorrect as the SHLAA shows the land as "Greenfield" with a use of "Agriculture". 3. The map referring to Stratford in Appendix C of the of the Urban Capacity Study is not clear in the area around site 592 due to the placing of "592" over the boundary line. It appears as though the part of the boundary of site 592 which runs across the back of the existing development is green whereas it should be yellow as this is the defined settlement boundary. 4. The latest version of the Stratford on Avon Site Allocations Plan shows 5 reserve sites earmarked to cover a dwelling shortfall of 516, namely, STR.11, STR.12, STR.14, STR.16 and STR.18. All of these sit outside the urban boundary. However only site STR.18 appears in the Urban Capacity Study, despite some of those other sites having a better Adjusted Overall Deliverability ranking than STR.18 in the Stratford on Avon SHLAA.

I agree that using brownfield land should be the priority. It turns unused, previously occupied space into usable land. If brownfield land isn't available, i don't believe greenbelt land should even be considered.

Firstly, the principle of intensification should be encouraged in all towns and cities. This will ensure that flats over shops are renovated and made commercially available, which would in turn improve the fortunes of the town and city centre high streets. Intensification in smaller towns and villages is also acceptable provided it suits the location and enhances the character of the existing village or town. Secondly, the use of brownfield sites should be encouraged and incentivized by government. Developers avoid brownfield sites if they can, preferring instead to take up and develop great swathes of green fields. This should not be allowed until both of the above have been fully achieved.

The urban capacity study identifies relatively little room for growth in the number of residential properties in existing urban areas. However, over the life of the local plan, major changes may increase this number. For example, 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 the feedback from the first consultation and associated commentary in the current consultation document provide compelling reasons to have strong policies to support intensification (issue S2). These include increasing active travel, maintaining local services and reducing the need to build on greenfield sites. Having a policy to support intensification should be used in conjunction with Option T1c about 20 minute neighbourhoods.

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.

Use Brown field sites for development using existing buildings to preserve the high grade agricultural land / green belt.

prioritice brownfield development and repurposing existing buildings

The overall consultation seems to ignore the brownfield first pledge that has been at both a local and national level. The paper lacks the recognition of the purpose of the urban capacity study which was to generate more efficient use of existing urban space seemingly defaulting to using greenfield sites to enable growth

I note the Urban Capacities Study was undertaken by a consultancy based in Solihull and therefore question the extent to which any local knowledge has been employed.

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