Q-S3.1: Please add any comments you wish to make about the Urban Capacity Study
No answer given
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, Richborough Estates 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.
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, Countryside Properties 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.
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, Bloor Homes 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.
Concern on using car parks, where there is only one car park in a rural town, this is likely to affect the viability of the town centre, especially if there are retail parks within a few miles allowing easy parking with a variety of retail outlets
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, Bloor Homes 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.
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 UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. On the basis of the above, MacMic Group consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period, in accordance with the HEDNA and should therefore represent the minimum housing requirement for the SWLP. In relation to capacity, the UCS considers housing supply, including sites with planning permission and outstanding allocations without planning permission across South Warwickshire, and other sources of potential supply within the urban areas. As the UCS assumes a Plan period from 2025, it is only sites with planning permission and outstanding allocations without planning permission which are scheduled to deliver in the period from 2025 onwards in the respective Housing Trajectories (at April 2021) which are included within the supply. Given MacMic Group consider a more appropriate Plan period commencement date is 2022, and given the respective April 2022 Housing Trajectories are now available, 20,695 dwellings is considered the accurate figure to be incorporated (on account of taking into consideration an additional three years of supply). The UCS incorporates a non-implementation deduction to be applied to site with planning permission at 5%, which is considered appropriate. With regard to outstanding allocations without planning permission across South Warwickshire, a comprehensive review is required to ensure that such sites meet the definition of Developable as set out in the NPPF . One such outstanding allocation which requires review is Long Marston Airfield which is allocated in the adopted Stratford-on-Avon Core Strategy (July 2016) for circa 3,500 dwellings (2,100 in the Plan period to 2031) and associated development. There are known issues with the delivery of the south-western relief road required to support the delivery of the new settlement at Long Marston Airfield, which combined with other infrastructure requirements is likely to be mean there is a significant lead-in time before development commences. The UCS seeks to increase the level of supply on four outstanding allocations without planning permission in Warwick District at Kenilworth and Whitnash by 323 dwellings, however this is considered to be questionable. There is the potential for these outstanding allocations without planning permission to come forward delivering a higher number of dwellings than is set out in the adopted Warwick Local Plan (September 2017). However, until such a time as planning permission is granted, there is insufficient certainty to make assumptions around level of delivery. In addition, it is noted that the Warwick Housing Trajectory (at April 2022) already incorporates increases in projected delivery on some outstanding allocations without planning permission, and thus this could constitute double counting. The UCS also seeks to include 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. It is noted that, to date, no formal assessment of these Call for Sites submissions has taken place in the emerging Housing and Economic Land Availability Assessment (HELAA). As such, the inclusion of these sites as potential supply in the UCS is unjust and these sites should be subject to formal assessment before being considered potentially suitable for allocation in the SWLP. Further, the UCS identifies an additional five sites on vacant land in the urban areas across South Warwickshire which have not yet been submitted to the Call for Sites process, but are considered potentially suitable in the UCS for 328 dwellings. Clearly there is insufficient certainty around the availability and deliverability of these sites which brings into question their potential for residential development. Further, on assessment of these sites there are some serious concerns around the suitability of these sites in any case. One example is Jephson’s Farm which is located north of the railway and Griffin Road in Leamington Spa, and is identified in the UCS as potentially suitable with a capacity of 171 dwellings. This land forms one of the last remaining gaps between Leamington Spa and Warwick so development is unlikely to be desirable, and further the site is highly constrained by flood risk and access limitations. As such, these five sites should be removed from the potential supply in the UCS as no evidence of their availability or deliverability has been provided. 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, but are considered potentially suitable in the UCS, again raising concerns around availability and deliverability. Talisman Square is subject to a current planning application for 44 dwellings on a larger site than identified in the UCS, but Westgate House has no planning history. As such, the inclusion of these two sites as potential supply in the UCS is unjust, and these sites should be subject to formal assessment before being considered potentially suitable for allocation in the SWLP Finally, the UCS considers the level of windfall allowance to be included in the supply in the SWLP. An assessment is provided showing level of windfall allowance in the respective adopted Local Plans and 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 likely sources/types of windfall supply (based on past trends) nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is considered likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence that it will provide a reliable source of supply, as required by the NPPF .
Use of existing brownfield land (and encouraging that in surrounding Housing areas) makes good sense and Lapworth parish Council would encourage consideration to be given to a "placemaking" approach rather than piecemeal activity as this will encourage people to want to live and work in brownfield areas. Use of brownfield land should be encouraged in preference to greenfield development and a higher weight should be given to this than the sustainable travel imperative.
It is considered that the urban capacity study it too optimistic in the number of dwellings to be located within existing urban areas. and is not supported by the historic evidence of windfall trends or the availability on the brownfield land register.
Brownfield sites must be prioritised. Class 3b agricultural land must not be considered for housing development.
There should be more support and encouragement of small business development allowing a new connection between the population and the land. Recycling units from decayed, demise building to more productive new premises. Think outside the box by engaging a representative section of society to investigate new options for work, leisure and homes in the 21st century.
Brownfield site classification needs to be clear. Rural areas with farm/commercial buildings should not be seen as brownfield ready for development. Brownfield needs to be focussed on releasing urban land for regeneration.
Would agree with using Brownfield sites rather than impacting Grrenbelt land.
The approach should always be to build on Brownfield land first. The developers argument that it is too expensive is simply a way to increase their profits. If only Brownfield land is available they will have to build on that. If not then they would soon go out of business.
I feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible then we should not turn to put development in the Greenbelt; the greenbelt should remain protected. Brownfield sites should be actively sought out. It is easier to develop fresh greenbelt land than it is to re use the Brownfield land. Appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as absolute priority.
There should be an explicit hierarchy applied: The use and re-use of brownfield sites should be given first priority for all the reasons indicated in the report. This priority should be reflected in the call for sites. Brown field sites should be actively sought out. Next non-green belt sites should be considered. Development on green belt land should be avoided as an absolute priority.
CPRE Warwickshire supports the option of using brownfield land for development. We stress that much of this comes through windfalls - planning applications for new housing or conversions to provide additional dwellings. 'Brownfield' and 'windfalls' are not the same, although some windfall housing is approved and delivered on what would be regarded as 'brownfield' - former industrial and commercial sites. The Urabn Capacity Study is a valuable source for proposed ways to use brownfield land and increase density of development in urban areas and in some villages. CPRE's submitted report on Housing and Employment Land Needs includes more detailed appraisal of the UCS.
no mention of brownfield first? green belt land should not be used just because desktop studies have not shown other options for development
I would support a policy of using brownfield land for development but only if it is done without detriment the existing townscapes. In towns such as Leamington Spa, Warwick, and Stratford upon Avon it would be utterly inappropriate to allow buildings that were disproportionately high or large in relation to their surroundings. Sadly, and almost without exception, the buildings that are most inappropriate in each of our towns and villages are those that have been designed and built the councils themselves. You only have to look at the Market Square in Warwick or as an extreme example the tower block in Lillington.
City and town centres should be re-developed first, to ensure that all accommodation above every shop or office is fully utilised. The government should revise VAT laws to incentivize renovations rather than encourage new buildings on green fields. And It is important to ensure that the Greenbelt in south warwickshire is protected as far as is possible.
23. 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 NPPF1. 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. 24. In relation to housing allocations from the adopted Local Plans, HLM 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 NPPF2. 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. 25. 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. 26. 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. 27. 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 3. 1 Paragraph 119 of the National Planning Policy Framework (July 2021) 2 Glossary of the National Planning Policy Framework (July 2021) 3 Paragraph 71 of the National Planning Policy Framework (July 2021)
21. 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 NPPF1. 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. 22. In relation to housing allocations from the adopted Local Plans, HLM 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 NPPF2. 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, in particular as development proposals will need to show at least a 10% Biodiversity Net Gain from November 2023. 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. 23. 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. 24. 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. 25. 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 NPPF3. 1 Paragraph 119 of the National Planning Policy Framework (July 2021) 2 Glossary of the National Planning Policy Framework (July 2021) 3 Paragraph 71 of the National Planning Policy Framework (July 2021)
5. 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 NPPF1 6. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. 7. On the basis of the above, MacMic Group consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period, in accordance with the HEDNA and should therefore represent the minimum housing requirement for the SWLP. 8. In relation to capacity, the UCS considers housing supply, including sites with planning permission and outstanding allocations without planning permission across South Warwickshire, and other sources of potential supply within the urban areas. As the UCS assumes a Plan period from 2025, it is only sites with planning permission and outstanding allocations without planning permission which are scheduled to deliver in the period from 2025 onwards in the respective Housing Trajectories (at April 2021) which are included within the supply. Given MacMic Group consider a more appropriate Plan period commencement date is 2022, and given the respective April 2022 Housing Trajectories are now available, 20,695 dwellings is considered the accurate figure to be incorporated (on account of taking into consideration an additional three years of supply). The UCS incorporates a non-implementation deduction to be applied to site with planning permission at 5%, which is considered appropriate. 9. With regard to outstanding allocations without planning permission across South Warwickshire, a comprehensive review is required to ensure that such sites meet the definition of Developable as set out in the NPPF2. One such outstanding allocation which requires review is Long Marston Airfield which is allocated in the adopted Stratford-on-Avon Core Strategy (July 2016) for circa 3,500 dwellings (2,100 in the Plan period to 2031) and associated development. There are known issues with the delivery of the south-western relief road required to support the delivery of the new settlement at Long Marston Airfield, which combined with other infrastructure requirements is likely to be mean there is a significant lead-in time before development commences. 10. The UCS seeks to increase the level of supply on four outstanding allocations without planning permission in Warwick District at Kenilworth and Whitnash by 323 dwellings, however this is considered to be questionable. There is the potential for these outstanding allocations without planning permission to come forward delivering a higher number of dwellings than is set out in the adopted Warwick Local Plan (September 2017). However, until such a time as planning permission is granted, there is insufficient certainty to make assumptions around level of delivery. In addition, it is noted that the Warwick Housing Trajectory (at April 2022) already incorporates increases in projected delivery on some outstanding allocations without planning permission, and thus this could constitute double counting. 11. The UCS also seeks to include 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. It is noted that, to date, no formal assessment of these Call for Sites submissions has taken place in the emerging Housing and Economic Land Availability Assessment (HELAA). As such, the inclusion of these sites as potential supply in the UCS is unjust and these sites should be subject to formal assessment before being considered potentially suitable for allocation in the SWLP. 12. Further, the UCS identifies an additional five sites on vacant land in the urban areas across South Warwickshire which have not yet been submitted to the Call for Sites process, but are considered potentially suitable in the UCS for 328 dwellings. Clearly there is insufficient certainty around the availability and deliverability of these sites which brings into question their potential for residential development. Further, on assessment of these sites there are some serious concerns around the suitability of these sites in any case. One example is Jephson’s Farm which is located north of the railway and Griffin Road in Leamington Spa, and is identified in the UCS as potentially suitable with a capacity of 171 dwellings. This land forms one of the last remaining gaps between Leamington Spa and Warwick so development is unlikely to be desirable, and further the site is highly constrained by flood risk and access limitations. As such, these five sites should be removed from the potential supply in the UCS as no evidence of their availability or deliverability has been provided. 13. 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, but are considered potentially suitable in the UCS, again raising concerns around availability and deliverability. Talisman Square is subject to a current planning application for 44 dwellings on a larger site than identified in the UCS, but Westgate House has no planning history. As such, the inclusion of these two sites as potential supply in the UCS is unjust, and these sites should be subject to formal assessment before being considered potentially suitable for allocation in the SWLP 14. Finally, the UCS considers the level of windfall allowance to be included in the supply in the SWLP. An assessment is provided showing level of windfall allowance in the respective adopted Local Plans and 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 likely sources/types of windfall supply (based on past trends) nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is considered likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence that it will provide a reliable source of supply, as required by the NPPF3. 1 Paragraph 119 of the National Planning Policy Framework (July 2021) 2 Glossary of the National Planning Policy Framework (July 2021) 3 Paragraph 71 of the National Planning Policy Framework (July 2021)
The true urban capacity of South Warwickshire needs to be established – the viability of developing these sites must be prioritised before developing green field sites. Option S3.2a: Prioritise brownfield development. Brownfield sites should be given the upmost priority and regeneration projects used to protect green belt areas. The decline in high street shopping areas means more residential use of these spaces should be considered.
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
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 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, 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 Greenbelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.
I feel that the use of Brownfield sites should be 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, 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.
My view is that the use of Brownfield sites should be prioritised. I do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenfield sites. 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.
Issue S2: Intensification: There are compelling reasons to have strong policies to support increasing active travel (cycling and walking), maintaining and improving public transport and local services and reducing the need to build on greenfield sites. Issue S3: Using Brownfield Land for development: Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.