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

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 support the preparation of the South Warwickshire Urban Capacity Study. It is a useful document to help understand the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements will be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. Certain brownfield sites may not be suitable for residential development on viability grounds, or unable to support a “full” S.106 package with reduced contributions towards affordable housing amongst other matters. This could be exacerbated by the introduction of NDSS policy and the other provisions of the emerging plan. That being the case, whilst we support the plan making the best use of previously developed land within the existing settlements as a possible location for residential development, these sites must be treated with caution. There is currently insufficient information available to establish the role these sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance accordingly.

3.12 The Study sets out that its purpose is to provide evidence that helps to reduce the need for development outside of South Warwickshire’s 23 existing urban areas as far as justifiably possible. Section 4.6 of the Study identifies that there is a total baseline housing supply for the 2025 -2050 Plan Period of 19,950 dwellings, of which 6,145 would be located within existing urban areas. Catesby Estates questions the robustness of this figure. The Study acknowledges it is a theoretical exercise without any reference to the application of policy or any other evidence base, including infrastructure requirements, deliverability etc. Paragraph 2.2.2 states that the: “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.” 3.13 Notwithstanding this, the Study compares this potential ‘supply’ against a housing need for South Warwickshire of 30,750 dwellings across the Plan Period. This figure is incorrect. The Consultation Document and HEDNA seeks to establish a ‘trend -based’ alternative to the Standard Method, which result in annual housing need of 868 dwellings per annum (Stratford) and 811 dwellings per annum (Warwick), totalling 1,679 dwellings per annum. Multiplied across a 25 -year Plan Period, this need is in fact 41,975 dwellings. This figure is importantly also exclusive of meeting any unmet need arising from neighbouring authorities, such as Coventry or Birmingham. 3.14 The identified potential ‘supply’, inclusive of sites within existing urban areas, is therefore less than half of the overall housing need required during the Plan Period. The Study acknowledges that brownfield land cannot be solely relied upon. We would encourage a more robust assessment of the sites to ensure the potential contribution to supply is established.

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.

We support the preparation of the South Warwickshire Urban Capacity Study. It is a useful document to help understand the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements will be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. Certain brownfield sites may not be suitable for residential development on viability grounds, or unable to support a “full” S.106 package with reduced contributions towards affordable housing amongst other matters. This could be exacerbated by the introduction of NDSS policy and the other provisions of the emerging plan. That being the case, whilst we support the plan making the best use of previously developed land within the existing settlements as a possible location for residential development, these sites must be treated with caution. There is currently insufficient information available to establish the role these sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance accordingly.

We have reviewed the Urban Capacity Study by Arup dated October 2022. Net of outstanding commitments and windfalls, it identifies an overall capacity of 1,231 dwellings. For the sake of comparison the Housing and Economic Development Needs Assessment (HEDNA) identifies a base annual housing need in South Warwickshire of 1,432 dwellings per annum (dpa). As such, even if all of these sites were to come forward at the assumed densities, their contribution to meeting housing need would be minimal. We also have concerns about the robustness of some of the sites identified as contributing towards urban capacity. For example, The Greens South of Alcester Road in Stratford-uponAvon is assumed to have a capacity of some 80 units when it was refused planning permission for 57 dwellings by the Council on heritage amongst other grounds. It is clear therefore that many of these sites will not proceed beyond the land availability assessment. We recognise that the Urban Capacity Study may not have looked at rural brownfield sites although given the sustainability challenges associated with such sites, they will likely make a negligible contribution. Accordingly, the evidence base shows that whilst brownfield development could always be prioritised, it will only make an at best marginal contribution towards meeting housing need on the council’s own evidence.

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.

2.21. The Urban Capacity Study identifies a potential baseline housing supply for the 2025-2050 plan period of 19,950 dwellings. Of this, 6,145 dwellings would be located within existing urban areas and the remainder located elsewhere (including new settlements). 2.22. The conclusion drawn at Section 4.6 of the Urban Capacity Study confirms that greenfield land must be released to meet South Warwickshire’s housing needs and states that: “….whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.” (Section 4.6, Page 37, own bold) 2.23. While the study indicates that the shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire this would seem highly unlikely given the significant programme of intervention and management that would be required for such capacity to be realised. The Respondent would also anticipate the likely yield from such sites to be considerably less than 3,400 dwellings and more likely towards the lower end of the range indicated (800 dwellings). 2.24. In the Respondent’s view, the inevitably of significant greenfield land being required adds considerably to the case for Green Belt release given that it is within the Green Belt that development can be most sustainably located. 2.25. It is agreed that to allow choice and competition in the market in accordance with National Planning Practice Guidance (NPPG) a buffer should be applied to the housing need as suggested in the Urban Capacity Study (Paragraph 4.6).

I do 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 is heavily biased 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. Appropriate planned development from the outset should avoid the use of “exceptional circumstances” to justify Green Belt incursions. Development on Green Belt land must be avoided as a 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.

11. 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. 12. 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. 13. 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. 14. 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. 15. 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)

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.

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

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

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

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 need for greenbelt development in "exceptional circumstances". Greenbelt development must be avoided the 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 do not consider that a policy should be included in the SWLP to prioritise the use of brownfield land for development. There is no such policy imperative set out within the NPPF, and as result were the SWLP to prioritise brownfield land over greenfield development it would be inconsistent with national policy and fail the tests of soundness. By way of context, it is important to note that prior to the publication of the NPPF in 2012 the concept of sustainable development was largely based upon the delivery of previously developed land, with an express sequential approach set out in PPG3 (latterly PPS3) and PPG1 (latterly PPS1). This sequential approach was specifically removed from national policy, and a more nuanced approach to sustainable development set out. There is no indication that a sequential approach is to be brought back in, despite the various revisions to the NPPF which have been published since 2012. This is because utilising brownfield land does not automatically render a proposal sustainable; and to prioritise brownfield land would be to bring forward development that does not meet the three pillars of sustainability and potentially unbalance plan strategy and plan delivery, since development would only be brought forward where brownfield land exists, not where the plan making process determined development should be. Policy can make clear that the emphasis should be on utilising brownfield land for development, but this must not be expressed as a sequential approach nor applied as such through the development management function.

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.

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.

Brownfield sites should clearly be highly prioritised and in all cases the development should not occur in Greenbelt land. The proposals do not call out sufficient identification of non-greenbelt / brownfield sites and these should be given a much higher priority. The consultation document is clearly heavily biased towards development in the greenbelt North of Leamington. This should be avoided at all costs and should only be considered in “exceptional circumstances”. No such circumstances are applicable.

Q-S3.1 - Urban Capacity Study: I feel that the use of brownfield sites should be prioritised; where brownfield development is not possible, development should not occur in greenbelt land. 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 (and unjustifiably) 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 believe 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.

Wellesbourne Matters supports the policy of prioritising brownfield development only when it corresponds with the identified growth strategy. Currently the entire curtilage of an airfield or airport is classified as ‘brownfield’ even though a significant proportion of the land itself may well have never been developed. The value of an airfield as an airfield should always exceed its value as a brownfield site put to other uses.

Q-S3.1 - Urban Capacity Study: I believe 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. The consultation document is heavily biased towards development in the greenbelt North of Leamington Spa and this should be avoided, especially when only 1/3 of the plan area is greenbelt. 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.

The South Warwickshire Urban Capacity Study is a useful document that confirms the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements could be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. l. In addition, a number of brownfield sites may not be suitable for residential development on viability grounds, or will be unable to support a “normal” S.106 package and result in reduced contributions towards affordable housing. This could be exacerbated by the introduction of NDSS standard housing and the other requirements of the emerging plan. Furthermore, the study does not consider the capacity of existing infrastructure to accommodate development, for example education and health. There may be infrastructure constraints that prevent some sites being developed, or a lack of service and facilities nearby that make sites unsustainable locations for residential development. There is currently insufficient information available to establish the role brownfield sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance.

I feel that the use of brownfield sites should be prioritsed and that where brownfield development is not possible, then non-greenbelt land should be used as an alternative avoiding development in the greenbelt. 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. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”.

To protect the viability of the town it has to be a mixture of both. We cannot stand still, howeverwithout a joined up approach to planning across the district this approach could overwhelm the existing infrastructure.