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ID sylw: 106507

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We support that the SWLP will be underpinned by a housing need and availability evidence base that
considers the Coventry and Warwickshire Housing Market Area as well as the Greater Birmingham and
Black Country Housing Market Area.
The latest Housing and Economic Development Needs Assessment (HEDNA) for Coventry and Warwickshire
(C&W) underscores the urgent need for a regional approach to addressing unmet housing demand. With an
annual housing requirement of 4,906 dwellings per annum (dpa) and a substantial shortfall in affordable
housing—3,833 rented affordable homes annually—Coventry faces the most significant pressure within the
sub-region. Given that 96% of Coventry’s affordable housing need remains unmet, it is imperative that South
Warwickshire plays an active role in accommodating this demand. Previous commitments, such as the
Memorandum of Understanding (MoU) between Coventry and Warwickshire authorities, have resulted in
Stratford-on-Avon and North Warwickshire allocating 2,880 dwellings to assist Coventry. However, these
allocations must be revisited within the South Warwickshire Local Plan (SWLP) to ensure a continued and
strategic approach to housing provision that aligns with the latest evidence base.
The SWLP must also recognise its strategic position within both the Coventry and Warwickshire Housing
Market Area (HMA) and the Greater Birmingham and Black Country HMA. Stratford-on-Avon has historically
contributed to both HMAs, with allocations of 2,720 dwellings for Greater Birmingham and Black Country
and 2,880 dwellings for Coventry and Warwickshire. As the plan extends to 2050, it must acknowledge the
ongoing cross-boundary pressures and proactively accommodate a proportionate share of the unmet
housing need. Deferring this responsibility to development management decisions or reserve sites would
undermine the plan-led approach required by the National Planning Policy Framework (NPPF). Instead, a
forward-looking policy framework should be established, ensuring that housing allocations
comprehensively address regional demands while balancing infrastructure capacity and sustainability
objectives.
Additionally, the SWLP must integrate a robust duty-to-cooperate mechanism, reflecting the demographic,
economic, and migration trends influencing South Warwickshire’s housing market. By proactively planning
for these needs now, the SWLP can provide certainty for local authorities, developers, and communities,
ensuring that housing growth aligns with economic and social sustainability. A clear strategy for
accommodating unmet housing need must be embedded within the plan to avoid the risks associated with
reactive policymaking, uncoordinated site releases, and an insufficient five-year housing land supply.

On this basis the clear indication now is that the SWLP will need to make a contribution by way of a duty to
co-operate and accommodate unmet housing needs arising from outside the SWLP plan area. It is
imperative that this is planned for now, having regard to NPPF paragraph 69. It is not appropriate to defer
the duty to co operate to reserve sites – which infers that a commitment to the duty to co-operate will be
deferred by stealth. The approach to deferring the duty to co-operate to the development management
function as a result of a deficiency against the 5-year housing land supply position is worse still. The
planning system is plan-led and the plan-led system should accommodate all of the housing needs arising
from both within the plan area and within the wider HMA’s. To do otherwise would be a serious failing of the
SWLP, a matter which would go to the heart of the plan and not able to be rectified through any
examination process or main modifications.