Issue and Options 2023

South Staffordshire Council welcomes the opportunity to submit comments at this early stage of the plan preparation process of the Joint South Warwickshire Local Plan 2050. The Council supports the decision to commit to the production of a new joint plan for Stratford-on-Avon and Warwick District Councils. The range of topics identified in the Issues and Options document does appear to broadly reflect the range of challenges and opportunities which need to be addressed by the new local plan. We support South Warwickshire taking a proactive approach towards meeting their housing need, recognising the issues with the standard method for the Coventry and Warwickshire Housing Market Area and promoting an alternative approach. We also support section H4 of the Plan which considers housing need arising from outside of South Warwickshire including from the Greater Birmingham & Black Country Housing Market Area (GBBCHMA). South Staffordshire District Council and Stratford-on-Avon District Council have been active members of the GBBCHMA Technical Officers Group since it was established in 2017 and both authorities have contributed to discussions relating to the delivery of unmet housing need within in the GBBCHMA. Both authorities are also party to the emerging 2022 GBBCHMA Development Needs Group Statement of Common Ground, which seeks to provide a programme of work and governance structure to address the housing shortfalls arising from the HMA. We therefore support the South Warwickshire Plan anticipating making provision for meeting a proportion of the shortfall from the GBBCHMA and encourage continued engagement with the GBBCHMA members. South Staffordshire Council has recently published an updated Gypsy and Traveller Assessment which has identified a need for 121 pitches during the plan period to 2039. South Staffordshire Council wrote to Stratford-on-Avon District Council (and other GBBCHMA and neighbouring authorities) in August 2022 where we set out that we had only identified a supply of 37 pitches to allocate against a 5-year requirement of 72 pitches. In the letter we set out the steps we had taken to explore supply options including exploring options in the Green Belt, options on publicly owned land, and options for new pitches as part of proposed housing allocations. In a Statement of Common Ground agreed in January 2023 between South Staffordshire and Stratford-on-Avon District Council’s paragraph 16 states: ‘In SSDC’s view, the established Greater Birmingham and Black Country Housing Market (GBBCHMA) is clear evidence of a functional link between both authorities and therefore requires that both authorities work together to address cross boundary housing matters (including Gypsy and Traveller provision). SoADC’s most recent response to the August 2022 correspondence stated that in view of the weak links between the two authorities and the likelihood that any provision made in Stratford-onAvon would not in reality meet actual needs arising in South Staffs, SoADC does not consider it appropriate to take unmet needs from South Staffs. Notwithstanding this, SoADC is keen to work with authorities across the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) in respect of evidence gathering to better understand these functional relationships. SSDC acknowledges that it has less of a functional relationship with SoADC than it does with some other authorities within the GBBCHMA, but believes it cannot be assumed that traveller families would be unwilling to relocate to a public site in SoADC’s administrative area if this secured them a permanent pitch. SoADC are Planning for Gypsies and Travellers through the preparation of the South Warwickshire Local Plan and have commissioned a GTAA to help inform that process. No decisions have yet been made about how needs will be met. In SSDC’s view it is therefore currently unclear as to what extent SoADC may or may not be able to assist in meeting unmet pitch need arising from SSDC until work on SoADC’s has been progressed.’ Within the Issues and Options Document, pitches and plots for gypsies, travellers and travelling showpeople are considered under Issue H6. Under this Issue the Plan states: ‘There are not enough sites across South Warwickshire for this type of accommodation and so we need to plan for more, up to date evidence is currently being prepared to identify what the need is for pitches and plots across South Warwickshire up to 2050. This may include a combination of both permanent and transit pitches and sites.’ We consider that the evidence being prepared should consider the links between South Warwickshire and South Staffordshire and we request that the South Warwickshire Local Plan considers the same steps that South Staffordshire has taken in exploring the four options for new pitches as set out in our letter dated 8th August 2022, including option for publicly run sites. As part of this we ask that you proactively explore whether any of South Staffordshire’s unmet need for pitches can be accommodated through proposals on existing or new public sites in the South Warwickshire Local Plan.

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We also support section H4 of the Plan which considers housing need arising from outside of South Warwickshire including from the Greater Birmingham & Black Country Housing Market Area (GBBCHMA). South Staffordshire District Council and Stratford-on-Avon District Council have been active members of the GBBCHMA Technical Officers Group since it was established in 2017 and both authorities have contributed to discussions relating to the delivery of unmet housing need within in the GBBCHMA. Both authorities are also party to the emerging 2022 GBBCHMA Development Needs Group Statement of Common Ground, which seeks to provide a programme of work and governance structure to address the housing shortfalls arising from the HMA. We therefore support the South Warwickshire Plan anticipating making provision for meeting a proportion of the shortfall from the GBBCHMA and encourage continued engagement with the GBBCHMA members. Within the Issues and Options Document, pitches and plots for gypsies, travellers and travelling showpeople are considered under Issue H6. Under this Issue the Plan states: ‘There are not enough sites across South Warwickshire for this type of accommodation and so we need to plan for more, up to date evidence is currently being prepared to identify what the need is for pitches and plots across South Warwickshire up to 2050. This may include a combination of both permanent and transit pitches and sites.’ We consider that the evidence being prepared should consider the links between South Warwickshire and South Staffordshire and we request that the South Warwickshire Local Plan considers the same steps that South Staffordshire has taken in exploring the four options for new pitches as set out in our letter dated 8th August 2022, including option for publicly run sites. As part of this we ask that you proactively explore whether any of South Staffordshire’s unmet need for pitches can be accommodated through proposals on existing or new public sites in the South Warwickshire Local Plan.