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

We note that the SWLP team have produced a density guide (January 2023) which illustrates typical housing densities found within the South Warwickshire Area. In respect of the LMA new settlement a density of 23dph is specified, based on an extracted block of development from Phase 1 only. It should be noted that the Long Marston Garden Village Framework Masterplan SPD (Feb 2018) specifies a range of densities according to specific location within the garden village and this ranges from 25-55 dph. The current and forthcoming development at LMA is being designed by Cala and determined by Stratford on Avon District Council on the basis of this document. Its density principles should therefore be carried across into any density guidelines set out within the SWLP.

Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

Over the life of the local plan it is possible that a reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites.

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.

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.

Use of Brownfield This is generally supported, however care needs to be taken on agreeing what is brownfield in the countryside. Some brownfield sites are naturally regenerating and are more valuable to nature conservation. On occasion their development will lead to sporadic development in the countryside and be environmentally undesirable.

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

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

Issue S3: Using brownfield land for development Given the scale of the national housing crisis, a combination of approaches for spatial planning is likely to be required. Furthermore, within the context of the Government’s levelling up agenda, it should be recognised that housing shortages and significant affordability issues remain. The Urban Capacity Study published as part of this consultation 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.’ The emerging plan will therefore need to consider brownfield land in conjunction with greenfield release. Brownfield sites are frequently found within towns and urban areas, where there is good availability of services, 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. Opportunities for densification of existing brownfield sites in locations well served by public transport should clearly be maximised wherever possible. The potential redevelopment of the Greenhill Street site offers such an opportunity for the Councils to deliver a significant number of dwellings within the town centre, close to public transportation.

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

Urban Capacity Study: We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, the development should not occur in Green belt 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, the development should not occur in Green belt 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.

A detailed study by Arup. I strongly support use of Brownfield as a first option, but where Brownfield sites will not meet planned housing needs , development of the Green Belt should not be substituted. I do not think that the call for sites approach has sufficiently prioritised the identification of non-Green Belt Brown or Greenfield sites. The consultation document shows a strong bias towards development in the Green Belt North of Leamington. This was avoided in the past Local Plans exactly because it was Green Belt. I see no justification for now planning to adjust Green Belt boundaries when 2/3rds of the SWLP area are outside of Green Belt. Good and appropriate planned development from the outset should avoid the use of “exceptional circumstances” to justify Green Belt incursions.

Q-S2: Please select all options which are appropriate for South Warwickshire Option S2b: In this option, the policy would apply across the whole of the South Warwickshire area. Design codes could still be drawn up for individual character areas, but it would also be prudent to have a more generic intensification design code that applied everywhere else. It may be difficult for this more generic design code to direct the most appropriate forms of intensification across a wide range of localities and architectural styles.

Issue S3: Using Brownfield Land for Development Historic England supports the sustainable re-use of land but would stress that the impact of brownfield development on the significance of heritage assets should be taken into account throughout the preparation of the local plan. We note that the Urban Capacity Study has defined character areas for a number of settlements utilising GIS data on historic buildings and conservation areas, amongst other data sets. With regard to the re-use of existing buildings we consider that the plan should recognise sustainability over the long-term. Historic buildings represent a significant investment of expended energy and demolishing and replacing them requires a major reinvestment of embodied energy and other resources. The local plan should therefore encourage and recognise the benefits of sympathetic restoration, retention, refurbishment and retrofitting of historic buildings.

The limitations of the Urban Capacity Study (Arup 2022) are highlighted in the report. The study is a theoretical exercise only. It is not intended to conclusively establish the urban housing capacity of South Warwickshire over the period to 2050. Instead it simply indicates potential urban housing capacity. More detailed work is required to confirm actual capacity. It is important to note that the study has not been informed by the outcome of an area-wide HELAA. The Urban Capacity Study concludes that there is a potential 19,950 dwelling supply (including windfall sites) and states that there is an additional potential up to 3,400 dwellings capacity that could be delivered on car parks. This means that in total up to 23,350 dwellings may be able to be delivered in urban areas in South Warwickshire. This assumes that all sites identified in the urban capacity study are deliverable and viable, and that the upper number of dwellings to be delivered on car parks is achievable. All of these assumptions require further testing, including on a viability basis, once the HELAA has been published. This identified capacity compares to a total baseline housing need in the area of 41,975 dwellings as calculated from the trend based calculation in the HEDNA, assuming a plan period from 2025-2050. This results in a c.18,625 dwelling shortfall (which could be higher once any cross-boundary apportionment of development from Coventry and / or Birmingham have been taken into consideration). The study concludes that it is unlikely to be possible to meet current development needs without significant greenfield development. However, in light of the figures set out above, the study should categorically conclude that a significant amount of greenfield development in sustainable locations will be required.

Issue S3: Using Brownfield Land for development Q-S3.1: Please add any comments you wish to make about the Urban Capacity Study 3.9 An Urban Capacity Study for South Warwickshire dated October 2022 has recently been undertaken to inform the SWLP. Its purpose is to identify the potential for residential development on brownfield land within existing settlements across 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 required outside existing urban areas. 3.10 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. 3.11 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 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. 3.12 Section 4.6 of the study provides a summary of the overall potential urban housing capacity across South Warwickshire: • Total housing assumed over SW area for the 2025-2050 plan period is 30,750 dwellings, using the baseline figures based on the standard method • Total potential baseline housing supply for this period is 19,950 dwellings • Only 6,145 (31%) dwellings would be located within existing urban areas, the rest is located elsewhere • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • Suggested there some potential to increase densities on some sites • Potential yield of 3,400 dwellings by redeveloping public car parks, but this would necessitate a significant programme of intervention and management in order to be realised. 3.13 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. 3.14 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.” 3.15 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. 3.16 The existing 2016 Stratford-upon-Avon Core Strategy identifies Lower Quinton as a Local Service Village under Policy CS15, which is also mirrored on the corresponding Key Diagram. This reflects the Council’s view of the settlement as a location for growth and development, and there is no logical reason why the settlement would be excluded from the nascent stages of plan making for the South Warwickshire Plan, as a spatial strategy has yet to be defined. RPS is unclear why Lower Quinton has been excluded both from the Plan and the supporting evidence base such as the Urban Capacity Study, a perverse position taken. 3.17 In terms of the evidence and the IO document, three options under this issue are presented. 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. Nonetheless, 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 up to 2050. Nonetheless, RPS would direct the Council to its response to Q-V3.1 above regarding the extension of the plan period. 3.18 On this basis, RPS supports Option S3.2c. In addition, given the fact the IO document and Urban Capacity Study has not reflected properly on the true scale of housing needed to be planned for across South Warwickshire or the current settlement hierarchy, Lower Quinton should be incorporated into a revised urban capacity study, and conclusions drawn on the ability of the settlement to accommodate additional growth within its built-up area.

There is compelling evidence on windfall sites that must be taken fully into account. The NPPF requires that this should be based on historic windfall delivery rates and expected future trends. As the Urban Capacity Study shows, the local plans have vastly under-estimated windfalls: windfalls have contributed much more in South Warwickshire than the sites allocated in the plans. It also gives the reasons why most windfalls are smaller sites and in urban areas. Recent events, such as Covid19 and the energy crisis, have led to less commuting to town centre offices and more internet shopping; these trends will lead to increased change of use in urban areas, further increasing windfalls. These will contribute greatly to both housing needs and changing employment needs, for example by converting redundant offices into research and development laboratories and shops into dwellings. If windfalls are taken fully into account, it is possible to meet genuine needs without greenfield development. It is essential that Brownfield First is fully embraced and pursued vigorously.

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritsed and that where Brownfield development is not possible, then development should not occur in Greebelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.

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 prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority

We feel that the use of Brownfield sites should be prioritised and that where Brownfield development is not possible, then development should not occur in Greenbelt land. In particular, we do not feel that the "call for sites" approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided as an absolute priority.

We feel that the use of Brownfield sites should be prioritsed and that where Brownfield development is not possible, then development should not occur in 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.

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

The Urban Capacity Study (October 2022) confirms that it has been undertaken as a theoretical exercise only. It is important to note that the study has not been informed by a Housing and Economic Land Availability Assessment (‘HELAA’). Therefore, the urban sites assessed in the study and have not yet been assessed by the Council so the urban capacity could actually be significantly lower than the 19,950 dwellings (excluding the additional 3,400 from potential car park redevelopment) quoted. It is important for the HELAA to be finalised and published as soon as possible so that we can better understand what the urban capacity is and what additional housing may be required elsewhere. Viability of delivering and relying on brownfield sites and the potential impact on affordable housing delivery will have to be a key consideration. In addition to reviewing the additional urban sites identified in the Study, it is also considered that the Councils should undertake a review of all of the adopted allocations which are not yet the subject of applications or delivered any dwellings (7,655 dwellings in total) and should provide evidence to justify why those sites are still considered to be deliverable within the SWLP plan period. Currently the 7,655 dwellings from existing allocations without planning permission form part of the total 19,950 dwellings identified in the Study. Table 2 within the Study shows the net developable area ratios which have been used (less than 1ha = 100%, up to 4.99ha = 90%, up to 9.99ha = 80% & 10+ha = 65%). There is no justification on how these ratios have been calculated. Bellway consider that the ratios are not realistic. There is no national planning guidance which sets out which ratios should be utilised. However, having reviewed other examples across England, Telford and Wrekin Council used 100% gross to net ratio less than 0.4ha, 75-90% up to 2ha and 50-75% over 2ha. It is considered that the range utilised by Telford and Wrekin Council offers more flexibility than the figures quoted within Table 2. Regardless of whether all of the sites are deliverable or not, the Study has identified that there will be a significant number of dwellings which will need to be identified on additional sites outside of the urban area. We await further confirmation of the proposed housing requirement figure and findings of the HELAA before commenting further on what we consider the shortfall of dwellings is.

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.