PAPER B2

Purpose: For Decision

REPORT TO THE EXECUTIVE

Date : 3 DECEMBER 2002

Title : URBAN CAPACITY AND THE MANAGED RELEASE OF HOUSING SITES – ADOPTION AS SUPPLEMENTARY PLANNING GUIDANCE (SPG)

REPORT OF THE PORTFOLIO HOLDER FOR AGENDA 21 AND COUNTRYSIDE MATTERS

IMPLEMENTATION DATE: 13 DECEMBER 2002

SUMMARY/PURPOSE

1. The purpose of this report is to consider the response to the Consultation Draft Urban Capacity Study and the Consultation Draft Phasing Report: Managed Release of Housing Sites and with the view to adoption of the reports (Attached as Appendices 2 and 3) as Supplementary Planning Guidance (SPG).

CONFIDENTIAL/EXEMPT ITEMS

2. There are no confidential or exempt items.

BACKGROUND

3. In order to ensure the application of the UDP properly reflects the guidance in PPG3, an Urban Capacity Study has been undertaken to assess the potential for brownfield development and its impact upon the release of greenfield allocations.

4. Review of the UDP is required to fully take into account the implication of the revised PPG3 (Housing), and in particular the issue of phasing of development sites using the sequential approach as directed in PPG3.

5. PPG3 highlighted the Government’s commitment to promote sustainable patterns of development, by maximising the re-use of previously developed land. The reasoning behind such an approach is twofold. Firstly it will promote urban regeneration; and secondly it will reduce the amount of greenfield land being taken for development. The national target for the re-use of previously developed land is that by 2008, 60% of additional housing should be provided on previously developed land and through conversion of existing buildings.

6. The UCS has been subject to two sets of consultation. The first an informal consultation with GOSE and other interested parties, to ascertain whether the there was agreement about the approach and methodology the Council were using. Several comments were received including comments from GOSE. The second was a formal consultation and copies were circulated to all councillors, Town and Parish Councils, GOSE, Developers, Housing Associations and agents and other interested parties.

STRATEGIC CONTEXT

7. Both documents will provide supplementary guidance to the Unitary Development Plan, which is a statutory planning document, which is required to comply with national planning policy guidance. The aims and objectives of the UDP are directly related to the corporate aims and objectives of the Council, and the vision of the Community Strategy.

OUTCOME OF CONSULTATIONS

8. The reports were circulated for formal consultation from 22^nd July 2002 until 20^th September 2002, and an advertisement placed in the County Press. The comments and responses are set out in detail in Appendix 1 of this report.

9. The Urban Capacity Study and Phasing Reports were reported to Select Committee on 24^th June 2002, and forwarded to Executive Committee for approval for consultation in July 2002

10. The Council have considered in full the response to the consultation on both reports and conclude that the Urban Capacity Study shows that there will be a need for both brownfield and greenfield housing developments to meet the Island’s housing requirements over the period 1996-2011.

11. In order to show that the release of necessary greenfield development is not compromising the opportunity to bring forward brownfield development sites it is necessary to consider how the release of sites will enable housing provision on the Island to be planned, monitored and managed in line with PPG3. This is undertaken in the phasing report. It concludes that:

12. Given the findings of the Urban Capacity Study and the current time frame of the IW UDP (1996-2011) it is considered that the allocated greenfield sites in the UDP are now brought forward for development in order to ensure that the Island, whilst continuing to promote the development of brownfield opportunities within existing towns, does not fail to meet the wider objectives of PPG3 in ensuring greater choice of housing, meeting the needs of affordability. This will hopefully support future sustainable economic prosperity for the Island as a whole.

FINANCIAL IMPLICATIONS

The report has direct financial implications for the Council in its role as Local Planning Authority.

The report may have financial implications for the Council in its role as land owner both in terms of the proposed phasing of the housing sites and the longer term use of its capital assets

LEGAL IMPLICATIONS

14. The guidance for the production and adoption of SPG is contained within PPG 12 and is an Executive function for the purposes of the Local Authorities (Functions and Responsibilities) Regulations 2000

15. As this is SPG, it will be open to challenge for the period of a potential judicial review

OPTIONS

16. That the Executive agree that the Urban Capacity Study and the Phasing Reports as amended, are adopted as Supplementary Planning Guidance.

17. Carry out further consultation.

18. Do not accept as supplementary planning guidance

EVALUATION/RISK MANAGEMENT

19. Not applicable.

RECOMMENDATION

20. That the Executive agree that the Urban Capacity Study and the Phasing Reports as amended (following consultation), are adopted as Supplementary Planning Guidance.

BACKGROUND PAPERS

Consultation Draft Urban Capacity Study and Phasing Reports, June 2002.

Isle of Wight Unitary Development Plan (May 2001).

PPG3 – Housing (2002)

Circular 01 /02 - Density Direction (2002)

PPG 12 – Development Plans 1999

ADDITIONAL INFORMATION

Appendix 1 – Comments on and response to the consultation on the Urban Capacity Study and Phasing Report.

Appendix 2 – Amended Urban Capacity Study

Appendix 3 – Amended Phasing Report

Contact: Ashley Curzon Wendy Perera

Principal Planning Officer (Policy) Senior Research Officer

Ext 4557 Ext 4596

[email protected] [email protected]

M J A FISHER

Strategic Director

Corporate and Environment Services

B LAWSON

Portfolio Holder for Agenda 21 and Countryside Matters

APPENDIX 1 – COMMENTS RECEIVED

GOSE Response on Urban Capacity Study

GOSE Comment	IW Council Response
Restrictive ceilings should not be placed on development. Max of 35dph could infer that development exceeding 35 dph would be unacceptable.	The Council will amend the Urban Capacity Study to provide a range of 30 minimum and 50 maximum, with a short piece of text discussing the current levels of density being achieved, and reference to densities in the range of 30-50 as set out in para 50 of PPG3. Although the UDP refers to the fact that 40dph is considered to be high-density development, PPG3 refers to densities of between 30-50 dph as being appropriate development standards. The UCS takes the approach laid out in PPG3 that a density range of between 30-50 provides housing development, which makes more efficient use of land. The Council will seek to provide greater intensity of development at places with good public transport accessibility such as a town or local centre and around major nodes along good quality public transport corridors. (Amendment included).
Further work on reducing car parking standards/introducing compulsory purchase etc mentioned in previous draft. Is it intended to carry out this work?	For information, the Council is considering reviewing its various policy areas as part of a comprehensive approach and this may come forward as part of the LDF. Reference to this will not be incorporated within the Urban Capacity Study. (No amendment made).
Development envelopes – infers that will not change. Tapping potential says should include all settlements that can contribute to sustainable patterns of development, including rural areas.	The UCS will be amended to clarify that the development envelopes are not under review as part of the Urban Capacity Study as they were recently reviewed as part of the UDP process. However, clearly there is a need to reflect the principles of PPG 3 paras 29-31 in considering development of brownfield sites. Development envelopes are drawn around settlements which include a range of facilities enabling the settlement to continue to function in a sustainable way. This approach is considered to allow existing sustainable settlements to retain their character, identity and viability and allow other settlements to accept beneficial development, which will enhance their ability to remain sustainable settlements This does not mean to say that brownfield sites outside of the development envelopes, which meet the requirements ofPPG3 paras 29-31, will not be considered. (Amendment included).
Have the previous comments from the development industry been taken into account in this report?	Previous comments have been taken into consideration, although in the main they related to affordable housing and thresholds rather than specific detail with regard to the methodology of the UCS. (No amendment included).
Empty properties – should not have double counting.	The UCS will be amended to clarify that empty properties are not included within the windfall capacity, and are dealt with as a separate capacity source. (Amendment included).
Suggests that housing allocations have not been reviewed in context of PPG3.	The UCS will be amended to clarify that the allocations were reviewed, and Inspector considered a number of sites, of which the allocated greenfield sites were considered to be the most sustainable. Inspector determined that sites were required to meet the housing provision figure. With reference to the sites identified in paragraph 3.2, all but 2 of these sites have been completed or are in the process of being built out. Both of the remaining sites are brownfield sites, and would now clearly have to be reviewed on the basis of PPG3. (Amendment included).
Allowance for windfalls not included in table 3.3	Windfall capacity has been included – but has been titled small sites capacity. The text will be amended to refer to windfall sites. (Amendment included).
Discount rate only applied to large sites – not other sources. Process should not be limited by expectations based on past performance.	The reason that sources other than large sites have not been discounted is that they are based upon past trends. Discounts for other sources were considered, ie supply is likely to become restricted as they are used up and therefore capacity would be reduced; on the other hand supply could be greater because of the emphasis placed on maximising the use of land. On balance it has been decided that a figure based upon past trends is likely to be the most reliable figure to include within the capacity study. (No amendment included).

GOSE response on the Phasing Report:

GOSE Response	IW Council Response
Need to establish the status of this document.	It is intended that the phasing report will be supplementary planning guidance to the consideration of the release of greenfield housing development, through the planning process. This will be set out in the introduction of the report. (Amendment included).
Why are the other “greenfield” allocations not included in the phasing document?	Para 6.5 refers to other greenfield sites and will be amended to reflect the impact that these sites could have on brownfield development. These sites total 3.63 ha, (and all are 1ha or below) which represents 7% of the total amount of greenfield allocations. It is considered that they will have a minimal impact upon brownfield development. All of these sites are within development envelopes, and perform well with regard to paras 29-31 of PPG3. They are not urban extensions, and are considered to be part of the urban fabric. (Amendment included).
Proposed monitoring needs to be fully explained. How will outstanding planning permissions and developments under construction be addressed through monitoring?	The phasing report will be amended to include details of how the release of greenfield sites will be monitored. Monitoring of completions and phasing of the greenfield sites will be linked into the annual housing monitoring process, which is already in place, and links with work undertaken by the regional assembly on an annual basis. Over the last two years a total of 1160 units have been completed, which is an average of 580 per annum. Over the last 6 months – April – September 2002, a total of approximately 200 units have been completed. Allowing for a slight upturn in completions, the likely outcome for total completions for 2003/03 is assumed to be in the region of 450-500 units. If the phasing of greenfield sites were such that they were all underway at the same time and built approximately 40 units per annum, this would equate to 240 units per annum, which would still require 54% of completions to come forward on brownfield sites. Current completions on large greenfield sites are at an average of 25-30 units per annum. If this rate were applied to all the new greenfield sites it would account for 150-180 units per annum, which would still require 65-70% of units to be built on brownfield sites. (Amendment included).

Other Representations on the Urban Capacity Study

Respondent	Summary of Response	Council Response
Carter Jonas, property consultants, on behalf of Wadham College.	Letter of support. Work clearly shows a need for release of greenfield land, not only to satisfy housing need supply issues, but also to achieve non-market housing provision.	Response noted. (No amendment included).
Brading Town Council	Support maximising the re-use of previously developed land. Need to address the issue of second homes. Need to increase the density at which sites are developed. Oppose the need to build 8,000 new homes on the Island.	Whilst the second home issue is of concern, the Council is not in a position to be able to affect/prevent second home ownership. Inclusion of an allowance for second homes would produce an unrealistic capacity figure. (No amendment included).
Gurnard Parish Council	Concern expressed over the greenfield site proposals. PC was not clear that there was a need for so much extra housing on the Island. Reports were noted and welcomed, and members await the final document.	The need for 8,000 houses on the island was established and confirmed by the Inspector during the UDP process. The role of the Urban Capacity Study is to inform how that 8,000 can be accommodated, making maximum use of brownfield development. (No amendment included).
Pro Vision, on behalf of Westbury Homes (Holdings) Ltd.	In agreement with the phasing proposals and in particular with the suggestion that the phasing of the Worsley Road site should fall within Phase 2 for the period 2004-2007.	Response noted. (No amendment included).
Shanklin Town Council	No comments to make upon the methodology used to conduct this study. Request for details of specific sites in Shanklin.	The aim of the Urban Capacity Study was not to be a sites specific document, but to provide a broad indication of the level of brownfield development that could be achieved on the Island. It should be noted that identification of potential does not automatically equate to granting of permission for residential development. (No amendment included).
Fuller Peiser, on behalf of Eton College.	Request that an area of land at Seaview, owned by Eton College, be included within the capacity study as being suitable for residential development.	The land in question is a greenfield site, and is allocated in the UDP as open space. The Council do not consider that this site should be included in the Urban Capacity Study (No amendment included).
Hawthorne Kamm, planning consultancy	Suggest a lower figure of 250 potential units on large brownfield sites. It would be useful if the large sites were identified. Because they make no direct impact upon the housing land supply, vacant properties should be ignored for the purposes of the urban capacity study. For conversions, a figure of 450 may be more appropriate. Agreement that it will be necessary to bring forward the greenfield sites, in particular because of their potential to contribute to affordable housing requirements.	The Council do not consider that they have over-estimated the potential of large sites. The approach taken, which includes an estimate for vacant properties is as outlined in the guidance to the preparation of an Urban Capacity Study, therefore the Council considers it appropriate to retain an estimate for this capacity source. (No amendment included).
Strutt & Parker, Property Consultants	No issues with regard to the content of the Urban Capacity Study.	Response noted. (No amendment included).
Calbourne Parish Council	Need to update the completions graph. Need to make people more aware of the development envelopes, in order to maximise the potential to identify brownfield sites.	The issue of development envelopes was discussed, and made widely public throughout the UDP process. Response noted. (No amendment included).
Wootton Bridge Parish Council	Infill within development envelopes should be considered prior to the release of greenfield land.	Response noted. (No amendment included).
Barratt, Southampton,	Relatively little capacity identified within the Eat Cowes area. Likelihood of such a high proportion of development coming forward on small sites is questionable. Overall figures given are too high.	The Council do not consider it appropriate to revise the estimate for capacity. (No amendment included).

Other Representations on the Phasing Report:

Respondent	Summary of Response	Council Response
Carter Jonas on behalf of Wadam College	Support release of Ashey Road site	Response Noted. (No amendment included).
Brading Town Council	If all houses were built at a higher density and second homes were taken into account there would be no need to release greenfield sites.	The density and second home issues have been dealt with as part of the discussion on the Urban Capacity Study. (No amendment included).
	Why are brownfield sites not appropriate for affordable housing?	Paragraph 5.4 makes the point that the size of brownfield sites falls below the threshold at which the authority can ask for a proportion of affordable units on the site. It does not mean that brownfield sites are inappropriate sites for affordable units. (No amendment included).
Pro Vision on behalf of Westbury Homes (Holdings) Ltd	Support the phasing proposals that the land at Worsley Road should fall within Phase 2 for development in the period 2004-2007.	Response noted. (No amendment included).
Hawthorne Kamm	Release of greenfield sites is unlikely to significantly compromise the development of brownfield land, given the results of the UCS. In particular the need affordable housing will be particularly affected should the greenfield sites NOT come forward. There is no need to phase the greenfield development sites as indicated in the report. The phasing of major greenfield sites should not proceed, as the UDP makes no reference to any phasing of development.	The Council are considering an alternative approach, which, rather than phasing the locations of development, it would phase the completions on sites, to enable development to come forward on all greenfield allocations. This would maximise the overall benefit for housing development on the Island. (Amendment included). The phasing of housing development was not mentioned in the UDP as the Inquiry was held prior to the release of guidance on the managed release of sites. The IW Council made a commitment to GOSE that on adoption it would review the plan with regard to the revised PPG3. The Urban Capacity Study and Phasing Report form part of this review.
Strutt & Parker	Note the need for greenfield land, but request that clients land at Gunville be considered a more appropriate site than that of the allocated site at Worsley Road.	The allocation of land for development is not a consideration of the phasing report, but a matter more appropriately considered via the UDP. A number of sites were considered at the UDP Inquiry, including land at Gunville, and the Inspector concluded that the sites greenfield sites allocated in the plan were the most appropriate for inclusion, and that there were no better greenfield alternatives. (No amendment included).
Barratt Homes	Concern that the land at Kingston is noted for phasing during the period 2007-2011. It potentially leaves Barratts with a 3-year break in continuity. Request that the phasing be more appropriate in 2004-2007. A more appropriate approach to phasing would be to phase the completions on sites, restricting the number of units that could come forward, rather than the location of units.	The Council together with SEEDA and the Isle of Wight Economic Partnership are taking a partnership approach to the regeneration of Cowes, East Cowes and the Medina Valley. Project Cowes will provide an overall framework for land use and development of a number of important sites to ensure Cowes, East Cowes and the Harbour can continue to deliver the expectations for employment, yachting, tourism, housing, leisure and nature conservation in a planned and agreed manner (Amendment included). The Kingston site provides for a mix of housing and waterside industry, with the industrial development reliant upon the provision of infrastructure and access from Whippingham Road. This is planned to be provided from the values associated with the housing part of the development. For this reason, the need to consider the site in the context of Project Cowes is an important consideration. The Council is however considering the approach suggested for phasing the number of units coming forward, as oppose to phasing the location of greenfield development. (Amendment included).

2. Study Method

2.1 The study has focussed wholly upon the identification of previously developed land that could potentially be suitable for new development. However, it should be recognised that some sites identified may be more appropriately utilised for uses other than housing, such as retail, or employment.

2.2 The study has been undertaken in a series of stages, which can be broadly described as follows:

1. Identifying capacity resources

2. Surveying the capacity

3. Assessing yield

4. Discount the potential to provide an assessment of the capacity that can be realised.

The remainder of this document deals with more detailed information with regard to the four stages listed above.

Identifying the area to be Assessed

2.3 The development envelope boundaries for urban and smaller settlement/village areas (regardless of size) have recently been confirmed through the UDP process. At the UDP Inquiry the Inspector heard a number of in depth arguments with regard to development envelope issues, and his report contained very few suggestions for changing either the Council’s approach to the use of development envelope boundaries to define the built extent of settlements; or site/settlement specific issues. The Unitary Development Plan was adopted on 18^th May 2001, and the study uses as its baseline the Development Envelope Boundaries as defined within Policy G1 of the adopted UDP.

2.4 The Development Envelopes are not under review as part of the Urban Capacity Study, as they were recently reviewed as part of the UDP process. However, clearly there is a need to reflect the principles of PPG3 paras 29-31 in considering development of brownfield sites. Development envelopes are drawn around settlements which include a range of facilities enabling the settlement to continue to function in a sustainable way, allowing existing sustainable settlements to retain their character, identity and viability and allow other settlements to accept beneficial development, which will enhance their ability to remain sustainable settlements. This does not mean to say that brownfield sites outside of development envelopes, which meet the requirements of PPG3 paragraphs 29-31, will not come forward.

2.5 There may be other settlements, which do not have defined development envelopes, but contain previously developed sites. These settlements are however deemed to be “countryside”, and not generally appropriate for new development (other than specific exceptions) and therefore they have not been included within this study. Such sites are not considered appropriate to include within the urban capacity study, as they would not contribute to sustainable patterns of development. Policy H9 of the UDP deals with such exception sites, which are by definition, sites only to be released where exceptional needs become evident, and they could be previously developed or greenfield sites. This approach is in line with government guidance which states that rural exception sites are in addition to identified capacity and that they relate to land that would not normally be released for housing. In any case, the capacity in such areas would be minimal.

2.6 Initial fieldwork included a full survey of all towns/villages with development envelopes, involving a comprehensive survey of all areas. The survey identified sources of capacity as outlines in the table over the page.

Identification of Capacity Sources

2.7The table below outlines the sources of capacity that were identified and are included within the urban capacity study.

Source	Description
Large sites – those previously developed sites that are over 1 ha in size.	Sites within existing defined development envelopes, which can be considered to be brownfield sites, as defined in Annex A of PPG3 have been identified. This included sites within single or multiple ownership, all previously developed vacant land, vacant land not previously developed and sites not otherwise allocated. Sites with the benefit of planning permission at December 2001 have been excluded from the survey.
Windfall sites – sites under 1 ha in size.	(See description above). Small sites make up a large proportion of the housing land availability stock on the Island. An assessment based upon past trends is considered to be the appropriate way of assessing the potential from such sites. Examples of such sites would be: flats over shops; infill plots; conversion of commercial buildings and existing housing. This does not include empty properties/vacant homes.
Vacant dwellings/empty properties	The annual average number of properties brought back into use via Housing Section funds.
Car Parks and Employment Land	All car parks, allocated employment land, and existing employment land within defined development envelopes was totalled. Assumptions will be made as to the proportion that is likely to come forward. Allocated employment land OUTSIDE of development envelopes has not been included
Conversions	Conversion of non-residential buildings.

2.8 The results of the initial fieldwork have been plotted onto a GIS and the data collated with regard to site size.

Assessment of Potential Yield.

2.9 This section assesses the potential for housing development within defined development envelopes for each of the listed sources in turn. The results have been achieved through a combination of site surveys and desk studies (as already discussed). The results provide a unconstrained capacity figure, which is the theoretical total number of dwellings that could be accommodated if all the potential capacity was developed optimally. Each capacity source outlined in the table above is discussed in more detail, and as assessed potential calculated.

Discounting the potential

2.10 It is however unrealistic to assume that the theoretical number of dwellings will be developed and the unconstrained figure needs to be adjusted based on the prediction of how much capacity can be brought forward by 2011. This is addressed through a “discounting” procedure, taking into account what is likely to be realistically achieved within the context established by PPG3.

2.11 In reaching appropriate discounting rates, “Tapping the Potential” draws attention to the need to take into account the developability of sites, including the willingness of owners to release the site for development, as well as physical constraints, market viability and character of the area. It provides ranges for each of the capacity sources and emphasises that the appropriate discount rate should be established by planning authorities, based on professional judgements, and knowledge of the area. For each of the capacity sources, an appropriate discount rate has therefore been applied and is explained in the discussion of each source.

Large Capacity Sites (over 1 ha)

2.12 A total of 19 sites have been identified, amounting to some 27.39 hectares of land. Current trends show that large housing sites are being developed at densities of 29 dph. This however includes all sites, both green and brownfield. Brownfield sites alone are currently being developed at densities of 28 dph. This figure is based on all sites currently included within the housing land availability database. In comparison, the 2000/2001 Local Best Value Performance Indicator shows that the average density of large housing sites was 26dph. Assumptions have therefore been based upon a minimum density of 30 dph and maximum density of 50 dph (as set out in paragraph 50 of PPG3). Although the UDP refers to the fact that 40 dph is considered to be high-density development, PPG3 refers to densities of between 30-50 dph as being appropriate development standards. The Urban Capacity Study takes the approach laid out in PPG3 that a density range of between 30-50 dph will provide housing development, which makes more efficient use of land. Current development averages 29 dph and the Council will seek to provide greater intensity of development at places with good public transport accessibility, such as towns or local centres and around major nodes along good quality public transport corridors.

2.13 An assessment has been made on the housing potential for each site, having taken into account any obvious constraints on development. The approach taken was consistent with the guidance in “Tapping the Potential”, in that a density multiplier was applied to each site. The density multiplier used was dependant upon the site size: 1-2 ha 75-90%; .2 ha 50-75%; and under 1 ha 100%. On larger sites there may be a need to take account of the provision of distributor roads, schools, open space serving a wider area and landscape strips, all of which reduce the developable area of a site.

2.14 This methodology has the benefit of being a practical way of dealing with sites and makes assessment more manageable because figures may be produced quickly and are consistent. The assessed capacity of this source amounts to between 600-700 units at a net density of 30dph and between 900-1200 units at a net density of 50 dph.

2.15 Not all large sites identified as suitable for housing are likely to be released and will be affected by factors such as willingness of owners to release land, infrastructure capacity, market viability and site amalgamation. They could also be affected by policy decisions such as compulsory purchase or revised parking standards.

2.16 Taking the assumption that such sites will be released in line with past trends. Large windfall sites are currently yielding an average of 27 dwellings per annum (based on data from the last 4 years). These sites have been single ownership sites that have been “easy” to develop. Only a small proportion of the urban capacity sites identified are single ownership, and it is felt that this will have an impact on the likelihood of the sites coming forward. Taking into consideration the multiple ownership issue, and assuming that the trend will continue, approximately 40% of assessed capacity is likely to come forward.

2.17 Using past trends the assessed capacity of this source amounts to between 250 and 500 units.

Windfall Sites (under 1 ha)

A total of 1000 sites were identified, covering some 143 hectares. The average site size was 0.13 ha. The study assumes that the majority of these sites will yield only 1 dwelling. Small windfall sites make up the largest proportion of capacity on the Island, as can be illustrated by the graph opposite.

2.18 In particular, this could have implications for the provision of affordable housing units, which can only currently be negotiated on sites meeting threshold criteria.

2.19 Projected small site figures based upon the last five years data suggest that an average of 140 dwellings per annum could come forward. Whilst this figure is higher than that identified from the capacity survey, it is considered inappropriate to use this trend, because the supply of small sites will be declining over the years.

2.20 This gives a potential assessed capacity of 1000 units.

Vacant/Empty Properties

2.21 The scope for bringing a significant number of vacant dwellings back into use is considered to be limited. The vacancy rate on the Island is comparable with the national rate. For this reason the Housing Section target figures have been used to make assumptions about the number of dwellings likely to come back into use. The target figure for re-use of empty properties is 26 dwellings per annum, however, the Housing Section is actually achieving approximately 30 dwellings per annum. It is assumed that this rate will continue for the foreseeable future. Vacant properties are not included within the windfall capacity or large site capacity (paras 2.12-2.20), and are dealt with as an entirely separate source.

2.22 The assessed potential of this source amounts to 300 dwellings.

Conversions

2.23 These are usually small sites, providing between 1 and 9 units per site. Conversions of non-residential properties and conversions of residential properties are currently providing an average of 75 units per annum. This study assumes that this rate will continue.

2.24 The assessed potential of this source amounts to 750 units.

Other Potential Sources

2.25 These sources include existing employment uses, allocated employment sites and existing car park sites. Open spaces and other green sites within development envelopes have been excluded from this study. The amount of employment land identified totalled 33.38 ha, and a further 13.44 ha of land currently used for car parking was also identified.

2.26 Car parks in particular are a sensitive subject, with PPG13 seeking less car parking and “Tapping the potential,” advising that even well used car parks can yield capacity. On the other hand, local businesses and town centre users often call for more car parking.

2.27 Existing employment uses and employment allocations probably offer the only real opportunity for large brownfield sites to come forward. However, the UDP includes employment policies that seek to retain existing employment uses and promote the employment allocations. Whilst mixed use is also promoted on some sites, it is difficult to estimate the potential from such sources, therefore it has been assumed that a minimum of 7% of the total area of car parks and employment uses will become available for residential development, at an average net density of 30 dph.

2.28 The assessed potential of this source amounts to 160 units.

2.29 The table below illustrates the total assessed yield from capacity sources.

Capacity Source	Assessed Yield
Large Sites	250-500
Windfall sites	1000
Empty Properties	300
Conversions	750
Car Parks/Employment Sites	160
Total	2460-2710

3. Overview of Supply of Housing Land

3.1 Current completion rates are over the minimum provision required by RPG9. This means that completion rates could fall below 520 per annum, but the total requirement from RPG9 could still be met. The chart below illustrates the completion data since 1991

Actual provision

RPG9 requirement

3.2 The elements of urban capacity discussed above are all subject to potential variations. The overall picture of supply of housing land also involves the housing allocations and extant approvals, which combine to make up the residential land availability database (not including greenfield sites). Assumptions have been made that 70% of residential land availability will be developed during the plan period. Housing allocations were revised as part of the UDP, on the basis of the principal of sustainability. The Inspector and the Council determined the need for the allocated greenfield sites, and no better sites were identified at the UDP stage.

The overall picture is shown in the table below:

Capacity Source	Yield (2001/2011)
Residential Land availability	2800
Large urban capacity sites	250-500
Windfall sites	1000
Empty properties	300
Conversions	750
Car parks/employment sites	160
Provision	5260-5510
RPG9 requirement to 2011	5200

3.3 The Council recognises that the potential identified on previously developed land through the urban capacity study may not be as great as some parties would wish, conversely it will be seen as an overestimate by others. The Council believes it is a realistic assessment.

4. Implications of the Urban Capacity Study for the UDP

4.1 The Urban capacity study cannot be seen in isolation. The results of the Urban Capacity Study will inevitably have implications in a number of areas, including the Council’s development resources, bids to other agencies, land assembly requirements, decontamination and parking and density standards and more importantly the potential revision of housing allocations. As already discussed in the introduction, the review of land allocations is the main reason for undertaking this study.

4.2 PPG3 provides guidance on a sequential approach to housing development, and the need to phase sites. The urban capacity study has illustrated that there is not enough brownfield land likely to become available to meet our housing need in the long-term.

5. Conclusion

5.1 Using the realistic capacity potential, the greenfield allocations contained within the UDP will still be required, but decisions remain to be made as to when these sites should come on-line. Consideration of phasing the release of allocated greenfield sites will be undertaken in the Supplementary Planning Guidance on the managed release of greenfield sites.

Appendix B

Below is a list of responses received to the consultation draft Urban Capacity Study.

The report was circulated, together with a report on the Phasing of greenfield allocations, to all Councillors, Parish and Town Councils, GOSE, Developers, Housing associations and other interested parties, for formal consultation from 22^nd July 2002 until 20^th September 2002.

Respondent	Summary of Response	Council Response
Carter Jonas, property consultants, on behalf of Wadham College.	Letter of support. Work clearly shows a need for release of greenfield land, not only to satisfy housing need supply issues, but also to achieve non-market housing provision.	Response noted.
Brading Town Council	Support maximising the re-use of previously developed land. Need to address the issue of second homes. Need to increase the density at which sites are developed. Oppose the need to build 8,000 new homes on the Island.	Whilst the second home issue is of concern, the Council is not in a position to be able to affect/prevent second home ownership. Inclusion of an allowance for second homes would produce an unrealistic capacity figure.
Gurnard Parish Council	Concern expressed over the greenfield site proposals. PC was not clear that there was a need for so much extra housing on the Island. Reports were noted and welcomed, and members await the final document.	The need for 8,000 houses on the island was established and confirmed by the Inspector during the UDP process. The role of the Urban Capacity Study is to inform how that 8,000 can be accommodated, making maximum use of brownfield development.
Pro Vision, on behalf of Westbury Homes (Holdings) Ltd.	In agreement with the phasing proposals and in particular with the suggestion that the phasing of the Worsley Road site should fall within Phase 2 for the period 2004-2007.	Response noted
Shanklin Town Council	No comments to make upon the methodology used to conduct this study. Request for details of specific sites in Shanklin.	The aim of the Urban Capacity Study was not to be a sites specific document, but to provide a broad indication of the level of brownfield development that could be achieved on the Island. It should be noted that identification of potential does not automatically equate to granting of permission for residential development.
Fuller Peiser, on behalf of Eton College.	Request that an area of land at Seaview, owned by Eton College, be included within the capacity study as being suitable for residential development.	The land in question is a greenfield site, and is allocated in the UDP as open space. The Council do not consider that this site should be included in the Urban Capacity Study
Hawthorne Kamm, planning consultancy	Suggest a lower figure of 250 potential units on large brownfield sites. It would be useful if the large sites were identified. Because they make no direct impact upon the housing land supply, vacant properties should be ignored for the purposes of the urban capacity study. For conversions, a figure of 450 may be more appropriate. Agreement that it will be necessary to bring forward the greenfield sites, in particular because of their potential to contribute to affordable housing requirements.	The Council do not consider that they have over-estimated the potential of large sites. The approach taken, which includes an estimate for vacant properties is as outlined in the guidance to the preparation of an Urban Capacity Study, therefore the Council considers it appropriate to retain an estimate for this capacity source.
Strutt & Parker, Property Consultants	No issues with regard to the content of the Urban Capacity Study.	Response noted.
Calbourne Parish Council	Need to update the completions graph. Need to make people more aware of the development envelopes, in order to maximise the potential to identify brownfield sites.	The graph will be updated. The issue of development envelopes was discussed, and made widely public throughout the UDP process. Response noted.
Wootton Bridge Parish Council	Infill within development envelopes should be considered prior to the release of greenfield land.	Response noted.
Barratt, Southampton,	Relatively little capacity identified within the Eat Cowes area. Likelihood of such a high proportion of development coming forward on small sites is questionable. Overall figures given are too high.	The Council do not consider it appropriate to revise the estimate for capacity.
Government Office for the South East	The comments from GOSE and the response o f the IW Council are set out separately in Appendix C

Appendix C

GOSE Response on Urban Capacity Study

GOSE Comment	IW Council Response
Restrictive ceilings should not be placed on development. Max of 35dph could infer that development exceeding this figure would be unacceptable.	The Council propose to revise the figures to provide a range of 30 minimum and 50 maximum, with a sort piece of text discussing the current levels of density being achieved, and reference to densities in the range of 30-5- as set out in para 50 of PPG3. Although the UDP refers to the fact that 40dph is considered to be high-density development, PPG3 refers to densities of between 30-50 dph as being appropriate development standards. The UCS takes the approach laid out in PPG3 that a density range of between 30-50 provides housing development, which makes more efficient use of land. The Council will seek to provide greater intensity of development at places with good public transport accessibility such as a town or local centre and around major nodes along good quality public transport corridors.
Further work on reducing car parking standards/introducing compulsory purchase etc mentioned in previous draft. Is it intended to carry out this work?	For information, the Council is considering reviewing its various policy areas as part of a comprehensive approach and this may come forward as part of the LDF. Reference to this will not be incorporated within the Urban Capacity Study.
Development envelopes – infers that will not change. Tapping potential says should include all settlements that can contribute to sustainable patterns of development, including rural areas.	The development envelopes are not under review as part of the Urban Capacity Study as they were recently reviewed as part of the UDP process. However, clearly there is a need to reflect the principles of PPG 3 paras 29-31 in considering development of brownfield sites. Development envelopes are drawn around settlements which include a range of facilities enabling the settlement to continue to function in a sustainable way. This approach is considered to allow existing sustainable settlements to retain their character, identity and viability and allow other settlements to accept beneficial development, which will enhance their ability to remain sustainable settlements This does not mean to say that brownfield sites outside of the development envelopes, which meet the requirements ofPPG3 paras 29-31, will not come forward.
Have the previous comments from the development industry been taken into account in this report?	Previous comments have been taken into consideration, although in the main they related to affordable housing and thresholds rather than specific detail with regard to the methodology of the UCS.
Empty properties – should not have double counting.	Empty properties are not included within the windfall capacity, and are dealt with as a separate capacity source. This will be made more clear in the text of the report.
Suggests that housing allocations have not been reviewed in context of PPG3.	Allocations were reviewed, and Inspector considered a number of sites, of which the allocated greenfield sites were considered to be the most sustainable. Inspector determined that sites were required to meet the housing provision figure. With reference to the sites identified in paragraph 3.2, all but 2 of these sites have been completed or are in the process of being built out. Both of the remaining sites are brownfield sites, and would now clearly have to be reviewed on the basis of PPG3.
Allowance for windfalls not included in table 3.3	Windfall capacity has been included – but titles small sites capacity. The text will be amended to refer to windfall sites.
Discount rate only applied to large sites – not other sources. Process should not be limited by expectations based on past performance.	The reason that sources other than large sites have not been discounted is that they are based upon past trends. Discounts for other sources were considered, ie supply is likely to become restricted as they are used up and therefore capacity would be reduced; on the other hand supply could be greater because of the emphasis placed on maximising the use of land. On balance it has been decided that a figure based upon past trends is likely to be the most reliable figure to include within the capacity study.

Managed Release of Housing Sites

1. Introduction

1.1 Following the adoption of the Unitary Development Plan (UDP) in May 2001 the Council has produced an Urban Capacity Study (UCS) in order to identify how the Council will ensure the provision of new housing development is in line with the objectives of PPG3. The UCS has shown that there will be a need for both brownfield and greenfield housing developments to meet the Island’s housing requirements over the period 1996 to 2011.

1.2 In order to show that the release of required greenfield development is not compromising the opportunity to bring forward brownfield development sites it is necessary to consider how the release of sites will enable housing provision on the Island to be planned,

monitored and managed in line with PPG3 objectives.

1.3 This document is intended to be used as Supplementary Planning Guidance to the implementation of the policies and proposals of the UDP (May 2001) and the aims and objectives of PPG3 – Housing (2000).

1.4 Although the UDP does not specifically refer to phasing of housing sites, the plan is based on the principles of sustainability as set out in PPG1, and there is clear intent within Policy S2 of the UDP to ensure brownfield sites are not compromised by the development of greenfield sites. Policy H3 of the plan goes on to state that allocated sites will be acceptable in principle, subject to any specific guidance as detailed. In addition, PPG3 – Housing, clearly states that its contents may well supersede the policies of adopted plans, and the Council wishes to ensure that the objectives of PPG3 are properly considered as part of the planning process.

1.5 This document has been subject to extensive public consultation and will assist in setting out the Council’s approach to releasing greenfield sites, within the context of the Urban Capacity Study, PPG3 and the UDP.

2. Background

2.1 The UDP sets out how the Council intends to meet the housing requirements of the Island over the plan period. A strategic policy of the plan (S2) states that development for housing will be encouraged on land which has previously been developed (brownfield sites) rather that undeveloped (greenfield) and therefore greenfield sites will only be allocated for development where no suitable alternative brownfield site exists. Policy S7 makes provision for the development of at least 8,000 housing units over the plan period and, whilst accepting that a proportion of these developments will occur on sites with existing allocations or planning approval, it states that enough new land will have to be allocated to ensure the target figure is met to provide both a range of choice and affordability.

2.2 Part II of the UDP sets out the detailed policies, proposals and justification for how the required housing will be met.

2.3 Policy H1 states that the majority of new residential development will be expected to be located within the defined envelopes of the main settlements (Cowes, East Cowes, Ryde, Newport, Shanklin and Sandown).

2.4 Policy H2 states that large housing allocation will be expected to provide a mix of dwelling types to reflect identified needs.

2.5 Policy H14 seeks to ensure at least 20% of units on large sites are affordable units to rent through an RSL.

2.6 In general the housing provision sought through the UDP is heavily reliant on windfall sites, extant consents and allocations in previous statutory plans. Much of this is defined as brown field development with only an additional 1,070 housing units identified on new sites to meet the 8,000 units.

2.7 Policy H3 of the UDP identifies the specific sites that have been identified in the plan for residential development and are set out in Appendix A of the UDP. The principal new greenfield sites allocated in the plan are as follows:

$ H3 (13) Land to the south east of Pan Estate, Newport - three areas of land totalling some 18.8ha.

$ H3 (16) Worsley Road, Newport - an area of land totalling some 8.8ha to the south west of Worsley Road.

$ H3 (18) Land to the rear of Ashey Road, Ryde. – the allocation totals some 6.5 ha, some of which already has the benefit of planning approval.

$ H3 (69) Land at Kingston, East Cowes - an area of some 6.5ha south of Kingston Farm Lane and west of Beatrice Avenue.

$ H3(18) Land at Sylvan Drive, Newport – 7.3ha of mixed brownfield and greenfield land, of which approximately 3.4ha is greenfield.

$ H3(64) Land at Sylvan Avenue, East Cowes – 1.6ha of land adjoining additional brownfield land, fronting Old Road.

2.8 In addition to the six sites listed above, there are a small number of other greenfield sites allocated in the UDP. These total some 3.6ha of land and all the sites are below 1ha in size. This represents only 7% of the total greenfield allocation. All the sites are located within the existing settlement boundaries and perform well against paragraphs 29-31 of PPG3.

2.9 These sites (in para 2.7) provide the main component of potential new greenfield development up to 2011 and are either located within the developed fabric of existing settlements or are urban extensions under the definitions in PPG3. At the UDP Inquiry, the Inspector considered that there were no better greenfield sites in terms of general sustainability criteria.

2.10 Although the UDP process preceded the publication of PPG3 the principal criteria for determining the acceptability of the new sites proposed are considered to be broadly in line with the objectives set out in paragraphs 30 and 31 of PPG3. This is particularly true in respect of issues such as location and accessibility, the capacity of existing and potential infrastructure, the ability to build communities, and the physical and environmental constraints on development of land. These issues are the primary determining factors in paragraph 31 of PPG3.

3. PPG3- Housing (March 2000)

3.1 PPG3 provides the Government’s up to date advice in respect of policy formulation and decision making in respect of new residential development. The principal objectives are that any plan should:

$ meet the need for the housing requirements of the whole community, including those in need of affordable and special housing

$ provide wider housing opportunity and choice including a better a mix in size, type and location

$ reuse of previously development land within urban areas in preference to development of greenfield sites.

3.2 The guidance is a fundamental change in government approach to planning for housing and it is made quite clear that LPA’s which produced plans prior to its publication ( such as the IW) may need to review and alter their plans in order to take on board PPG 3's key objectives.

3.3 Para 33 of PPG3 states that local authorities should manage the release of sites over the plan period in order to control the pattern and speed of urban growth and suggests that phasing the release of land for housing over the plan period will seek to ensure the presumption that previously developed land will be developed before green field sites whilst enabling plan, monitor and manage to be implemented.

5.5 Although the objective of developing brown field land will continue to be promoted, the requirements of PPG3 must be assessed in its widest context by providing for mixed communities and a choice of housing. The established and identified need for affordable housing borne out by the Housing Needs Survey 2001, must be balanced against the promotion of brown field development. The inevitable consequence of focussing and relying too heavily on previously developed land to provide most or all of the Island’s housing requirements in terms of numbers, will mean that the Island’s need for further affordable rented accommodation could be compromised further.

6. Phasing

6.1 In the past large scale housing development on the Island has been phased over a number of years reflecting the steady and anticipated market for new housing. The existing Carisbrooke Estate, Newport, is a good example of this. Although the housing market on the Island has changed in recent years reflecting a growing interest from second home owners and the presence of national builders such as Barratt, Persimmon and Westbury Homes it is still likely that any new housing allocations which are released for development will take a number of years to develop irrespective of any phasing constraints placed on sites through the planning process. Research into completions on existing greenfield sites over the past 2 years indicate that on large sites some 25-30 units per annum have been completed. This shows that even during a buoyant period of housing development with unrestricted approvals, the nature of development on the Island limits greenfield new build.

6.2 In this context the deliverability of allocated greenfield sites in the UDP needs to be examined in respect of the need to provide for 8,000 new units up to 2011. The graph below indicates the rate at which sites have been developed in the period 1996-2001. Up until 2002 sites were being developed at a rate higher than that required by RPG9. However, during the last financial year, completions fell dramatically to 383. There is a need for the planning process to ensure that the RPG9 target of 520 units per year can continue to be met.

6.3 The start date of the UDP is 1996 and therefore 6 years of the Unitary Development Plan (UDP) period have already lapsed. Over this period of the plan (1996 - 2002) housing units delivered on the Island consisted mainly of brownfield sites with a small number of greenfield sites, the result of extant planning approvals from allocations in previous local plans.

6.4 There are a total of 105 sites allocated in the UDP. Of these, a small number were greenfield sites. The following list contains greenfield sites which do not have the benefit of an extant permission:

· Land to the South East of Pan Estate, Newport (18.8 ha).

· Worsley Road, Newport (6.7 ha).

· Land to rear of Ashey Road (4.4).

· Land at Kingston, East Cowes (10.5 ha).

· Sylvan Drive, Newport (3.5 ha)

· Sylvan Avenue, East Cowes (1.6 ha)

There are a small number of additional greenfield sites, totalling 3.63 ha (and all are 1 ha or below in size), representing 7% of the total amount of greenfield land allocated, which are not included in the above list. It is considered that they will have minimal impact upon brownfield development. All of these sites are within development envelopes, and perform well with regard to paragraphs 29-31 of PPG3. They are not urban extensions and are considered to be part of the urban fabric.

6.5 It is anticipated that at a density range of 30-50 dph on the sites listed could provide between 1300 and 2300 units.

6.5 Of the six major green field sites listed above only Ashey Road at Ryde and Sylvan Drive, Newport have been progressed to planning application stage . The remaining sites are at best in the preliminary/master planning stages and are unlikely to be ready for development to take place until 2004 at the earliest. With the principal objective of PPG3 being the need to maintain a sufficient supply of housing over a five-year period and the UCS indicating that all green field sites will be required to deliver that supply, the feasibility of bringing forward all major greenfield allocations should now be considered if they are to be required by 2011.

6.6 If all the greenfield sites were now released for development, it would be at least 2 years before there were any significant completions. Furthermore, at a rate of 25-30 units per year being developed by each site, this would equate to between 150 and 180 units from greenfield allocations, which set against RPG9 requirements of 520 units per annum, would still only represent between 29-35% of the total. The remainder of completions would be from Brownfield sites.

6.7 The consequences of delaying the planning and release of sites may therefore result in housing supply being severely diminished. This could lead to higher house prices; consequent reductions in affordable housing in both the rented and owner occupied sectors and related economic and social consequences for the Island well beyond housing supply issues.

7. Approach For the Release of Greenfield Sites

7.1 Given the findings of the Urban Capacity Study and the need for greenfield sites allocated in the Unitary Development Plan to come forward by 2011 in order to meet housing needs, it is suggested that the sites below are now released for development in order to meet the housing needs of the Island. Rates of development on the larger sites (Pan and Kingston) will mean that these are unlikely to be developed out during the plan period, and all sites will be phased and monitored to ensure that wider housing objectives are met.

1. Ashey Road, Ryde – the remainder of this allocated site is already at the outline planning application stage and could progress in the short term if consent is granted. The housing needs survey identifies a major shortage of affordable housing in the Ryde area which could be partly addressed by the development of this site. Given the need to resolve land ownership, Section 106 Agreement and detailed planning issues, it is still unlikely that any development would commence until late 2003/early 2004.

2. Pan and Worsley Road sites, Newport - both these large greenfield allocations are urban extensions to the main settlement and growth area of the Island. Both sites are at a preliminary stage in terms of master planning and the Council anticipates that in respect of Pan, that development would be unlikely to proceed following necessary consultation, much before 2004. A similar scenario would be expected to take place in respect of the Worsley Road site with a similar timetable. As well as being a major focus for new housing development Newport is also experiencing growth in other sectors such as retailing and employment and industrial development and it is important to ensure that this sustainable economic growth is not compromised by a shortage of housing provision.

3. Kingston, East Cowes - East Cowes has been experiencing significant changes over the past 12-18 months, both in respect of major new housing developments taking place within the area and also uncertainty over the future use of GKN Westland’s site.

3.1 The Council together with SEEDA and the Isle of Wight Economic Partnership are taking a proactive approach to the regeneration of Cowes, East Cowes and the Medina Valley. Project Cowes will provide an overall framework for land use and development of a number of important sites to ensure Cowes, East Cowes and the Harbour can continue to deliver the expectations for employment, yachting, tourism, housing, leisure and nature conservation in a planned and agreed manner

3.2 The Kingston site provides for a mix of housing and waterside industry, with the employment/industrial development reliant upon the provision of infrastructure and access from Whippingham Road. This is planned to be provided from the values associated with the housing part of the development. As part of the appraisal and future use of existing employment sites in the area, through Project Cowes, the Kingston site could play a role in a comprehensive approach to the regeneration of Cowes and East Cowes and should be properly considered within this context.

4. Sylvan Avenue, East Cowes – The allocation, which is in part owned by the Council, is likely to form part of the consideration within the wider “Project Cowes” proposals. As a partner organisation with SEEDA and IWEP, the Council will need to ensure that this area of land is considered, if necessary, as part of a package for the regeneration of the area, and is unlikely to come forward prior to 2004.

5. Sylvan Drive, Newport – The allocation is a mix of brown and greenfield land, located close to the centre of Newport, with strong sustainability credentials, when considered against paras 29-31 of PPG3. Part of the allocation is the subject of a current outline planning application and should be progressed in a way that ensures the development of an important element of brownfield housing land in conjunction with the greenfield element. It is unlikely that any development/completions will occur on site before 2004.

7.2 The diagram on the next page illustrates the likely timescale for development to begin on the strategic greenfield sites:

Phase I

1996-2003

Phase II

2004-2011

Already

developed

Site A – Ashey Road

Site C - Pan

Site B – Sylvan Drive, Newport

7.3 Throughout the process, the rate at which brownfield sites are being developed will be monitored. This is in line with the sequential approach as set out in PPG3. If monitoring indicates that sites are not coming forward at the desired rate, it may be appropriate to consider adjustments to the phasing of sites. The Council does not intend to phase the existing brownfield allocations/commitments.

7.4 In order to ensure that the release of greenfield housing does not compromise continuing development of brownfield sites, it is intended that the release of the major sites will be phased for completion through the planning application process, at up to 50 units per annum. Releasing all the sites and allowing them to be developed concurrently, will ensure that there is effective competition in the market place, which should in turn ensure that housing needs in those main towns can be met.

8. Conclusion

8.1 Given the findings of the Urban Capacity Study and the current time frame of the IOW Unitary Development Plan (1996-2011) it is considered that the allocated greenfield sites in the UDP are now brought forward for development. This is to ensure that the Island, whilst continuing to promote the development of brownfield opportunities within existing towns, does not fail to meet the wider objectives of PPG3 in meeting its housing targets, ensuring greater choice of housing and meeting the needs of affordability. This will hopefully ensure future sustainable economic prosperity for the Island as a whole.

8.2 There is a strong case for the Kingston site at East Cowes (which includes a large proportion of industrial land) to be delivered as part of the wider regeneration initiative taking place under Project Cowes.

Appendix A

Below is a list of responses received to the consultation draft Phasing Report – The Managed Release of Greenfield Sites.

The report was circulated, together with a report on the Phasing of greenfield allocations, to all Councilors, Parish and Town Councils, GOSE, Developers, Housing associations and other interested parties, for formal consultation from 22^nd July 2002 until 20^th September 2002.

Respondent	Summary of Response	Council Response
Carter Jonas on behalf of Wadam College	Support release of Ashey Road site	Response Noted.
Brading Town Council	If all houses were built at a higher density and second homes were taken into account there would be no need to release greenfield sites.	The density and second home issues have been dealt with as part of the discussion on the Urban Capacity Study.
	Why are brownfield sites not appropriate for affordable housing?	Paragraph 5.4 makes the point that the size of brownfield sites falls below the threshold at which the authority can ask for a proportion of affordable units on the site. It does not mean that brownfield sites are inappropriate sites for affordable units.
Pro Vision on behalf of Westbury Homes (Holdings) Ltd	Support the phasing proposals that the land at Worsley Road should fall within Phase 2 for development in the period 2004-2007.	Response noted.
Hawthorne Kamm	Release of greenfield sites is unlikely to significantly compromise the development of brownfield land, given the results of the UCS. In particular the need affordable housing will be particularly affected should the greenfield sites NOT come forward. There is no need to phase the greenfield development sites as indicated in the report. The phasing of major greenfield sites should not proceed, as the UDP makes no reference to any phasing of development.	The Council are considering an alternative approach, which, rather than phasing the locations of development, it would phase the completions on sites, to enable development to come forward on all greenfield allocations. This would maximise the overall benefit t for housing development on the Island. The phasing of housing development was not mentioned in the UDP as the Inquiry was held prior to the release of guidance on the managed release of sites. The IW Council made a commitment to GOSE that on adoption it would review the plan with regard to the revised PPG3. The Urban Capacity Study and Phasing Report form part of this review. Additionally, whilst the UDP does not specifically refer to phasing of housing sites, the plan is based on the principles of sustainability as set out in PPG1, and Policy S2 of the UDP deals with the need to release brownfield sites prior to greenfield sites. PPG3 – Housing also clearly states that its contents may well supercede the policies of adopted plans, and the Council wishes to ensure that the objectives of PPG3 are properly considered as part of the planning application process.
Strutt & Parker	Note the need for greenfield land, but request that clients land at Gunville be considered a more appropriate site than that of the allocated site at Worsley Road.	The allocation of land for development is not a consideration of the phasing report, but a matter more appropriately considered via the UDP. A number of sites were considered at the UDP Inquiry, including land at Gunville, and the Inspector concluded that the sites greenfield sites allocated in the plan were the most appropriate for inclusion, and that there were no better greenfield alternatives.
Barratt Homes	Concern that the land at Kingston is noted for phasing during the period 2007-2011. It potentially leaves Barratts with a 3-year break in continuity. Request that the phasing be more appropriate in 2004-2007. A more appropriate approach to phasing would be to phase the completions on sites, restricting the number of units that could come forward, rather than the location of units.	The Council together with SEEDA and the Isle of Wight Economic Partnership are taking a partnership approach to the regeneration of Cowes, East Cowes and the Medina Valley. Project Cowes will provide an overall framework for land use and development of a number of important sites to ensure Cowes, East Cowes and the Harbour can continue to deliver the expectations for employment, yachting, tourism, housing, leisure and nature conservation in a planned and agreed manner The Kingston site provides for a mix of housing and waterside industry, with the industrial development reliant upon the provision of infrastructure and access from Whippingham Road. This is planned to be provided from the values associated with the housing part of the development. For this reason, the need to consider the site in the context of Project Cowes is an important consideration. The Council is however considering the approach suggested for phasing the number of units coming forward, as oppose to phasing the location of greenfield development.
Government Office for the South East	GOSE comments and our response are detailed in Appendix B

Area	Type	Ha
Cowes	Large sites	0.00
Cowes	Small sites	14.17
East Cowes	Large sites	0.00
East Cowes	Small sites	8.92
Newport	Large sites	14.13
Newport	Small sites	26.34
North East Wight	Large sites	2.61
North East Wight	Small sites	42.58
South East Wight	Large sites	2.67
South East Wight	Small sites	20.86
West Wight	Large sites	4.35
West Wight	Small sites	9.28
Rural towns & Villages	Large sites	5.06
Rural towns & Villages	Small sites	21.62

PAPER B2

SUMMARY/PURPOSE

CONFIDENTIAL/EXEMPT ITEMS

BACKGROUND

BACKGROUND PAPERS

ADDITIONAL INFORMATION

APPENDIX 1 – COMMENTS RECEIVED

GOSE Comment

GOSE Response

IW Council Response

APPENDIX 2 – URBAN CAPACITY REPORT

Supplementary Planning Guidance, November 2002

Urban Capacity Study

1. Introduction

2. Study Method

Identifying the area to be Assessed

Identification of Capacity Sources

3. Overview of Supply of Housing Land

4. Implications of the Urban Capacity Study for the UDP

5. Conclusion

Appendix A

Appendix B

Appendix C

GOSE Comment

APPENDIX 3 – PHASING REPORT

Supplementary Planning Guidance, November 2002

Managed Release of Housing Sites

1. Introduction

2. Background

3. PPG3- Housing (March 2000)

4. Urban Capacity Study

5. Isle of Wight Housing Needs Survey 2001

6. Phasing

7. Approach For the Release of Greenfield Sites

8. Conclusion

Appendix A

Appendix B

GOSE Comments on Phasing Report

GOSE Comment

IW Council Response