BASE HEADER

Other

ID sylw: 108189

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy Direction 4- Accommodating Growth Needs Arising from Outside South Warwickshire? 2.41 Whilst St Philips welcomes the SWA’s acknowledgement that the SWLP may need to play a role in addressing the unmet housing need of neighbouring authorities within the Coventry & Warwickshire Housing Market Area [C&WHMA]2 and Greater Birmingham and Black Country Housing Market Area [GBBCHMA]3, St Philips has some concerns regarding the SWLP’s proposed approach. 2.42 The SWLP proposes – albeit not explicitly – to only assist with addressing the unmet housing needs of the C&WHMA and GBBCHMA only when it these unmet needs are defined, and through the release of ‘reserve sites’. However, the PO does not identify, at this stage, any ‘reserve sites’, nor does the PO’s commentary on the proposed spatial strategy speak to this matter. 2.43 Importantly, the NPPF emphasises that local planning authorities [LPAs] must cooperate to identify and meet housing needs within their housing market areas [HMA] (Para 11b), and that plans should be supported by relevant and up-to-date evidence (Para 32). It also reiterates that LPAs’ continue to be under a Duty to Cooperate [DtC] (Para 24). It is also clear that:
“Plans come forward at different times, and there may be a degree of uncertainty about the future direction of relevant development plans or the plans of infrastructure providers. In such circumstances strategic policy-making authorities and Inspectors will need to come to an informed decision on the basis of available information, rather than waiting for a full set of evidence from other authorities.” (Para 28) 2.44 In this context, given the acuteness of the situation in these HMAs – outlined in detail below – it will be necessary for the SWLP to make provision for any unmet housing needs arising from these HMAs at the point of adoption, rather than deferring this matter to a time when the unmet needs have been ‘evidenced’ and through the release of ‘reserve sites’. Indeed, this is particularly pertinent, given the Inspector’s recent findings in respect of the Solihull Local Plan Review where problems of Birmingham’s unmet need were not adequately addressed within the plan, resulting in a terminal failure of the soundness of the plan. 2.45 It is noted that there is no single, or definitive, approach to determining the proportion of unmet needs that any single area should accommodate. In any event, given that the SWLP area sits within the two HMAs, both with serious historic housing land supply challenges, St Philips considers that there is an extremely high level of certainty based on the current evidence that the SWLP will need to accommodate some of these needs. 2.46 By way of example, whilst there is some degree of uncertainty regarding whether there will be any unmet housing needs arising from the C&WHMA, it is plain to see that the SWLP will need to assist in meeting the unmet housing needs of the GBBCHMA up to 2042 at the very least. Indeed, despite the revisions to the NPPF and SM alleviating pressures in the GBBCHMA in part,4 a significant housing shortfall across the GBBCHMA remains, with an estimated cumulative shortfall of c.42,900 homes across the WMCA up to 2042 under the SM, arising from the Black Country Authorities [BCAs].5 To address these needs, the BCAs are actively seeking to export these needs into the GBBCHMA – of which the SOADC falls within – to be addressed through the forthcoming Local Plan. 2.47 At present, only Shropshire (1,500), South Staffordshire (640), Cannock Chase (500), Stafford (2,000) and Telford & Wrekin (1,6806) are proposing to contribute towards addressing these unmet housing needs. Collectively, this would equate to only 6,320 dwellings between 2018 and 2042, but, notably, several of these plans have stalled or are at risk of being found unsound in due course. Notwithstanding the uncertainty regarding these ‘contributions’, a significant unmet housing need would still remain within the GBBCHMA. As such, at present, there is an unaccounted shortfall up to 2042, which is substantial given the urban context of the BCAs, meaning that a significant proportion of the unmet need will be deferred rather than dealt with, contrary to paragraph 35c of the current NPPF. This highlights the importance of SWAs effectively delivering on their DtC. 2.48 Ultimately, there is a significant, and persistent level of unmet housing need across the GBBCHMA and even with some Green Belt releases in the BCAs it is unlikely to markedly reduce the GBBCHMA’s significant shortfall of housing. To this end, the SWAs and wider GBBCHMA authorities will need to make appropriate contributions towards addressing these needs now. As such, whilst there remains some uncertainty regarding the exact amount of unmet housing needs, under the revised NPPF, the SWLP will need to make provisions based on the current level of information, rather than deferring until these unmet needs are defined. 2.49 In terms of how much of these needs the SWAs should be addressing through the SWLP, it is noted that there is not a single, or definitive, approach to determining the proportion of unmet needs that any single Council should accommodate. That being said, the NPPF is clear that Local Plans should be based on ‘proportionate evidence’ (Para 35c). 2.50 However, as the SWAs will be aware, Lichfields has historically provided an evidence-led approach for how to distribute previous unmet housing needs sustainably. In particular, Lichfields’ Black Country’s Next Top Model analysis considers the functional housing market relationship between the various local authority areas in the GBBCHMA and the origin-authorities of the unmet housing needs. 2.51 It should be noted that of the current contributions towards the BCA's unmet needs, Wolverhampton has highlighted that the BCAs are attributing proportions based on migration trends: “is important to develop an evidence-led approach to dividing up such contributions between authorities across the wider Greater Birmingham and Black Country Housing Market Area (HMA) which have a housing shortfall. The proposed approach, which has been agreed by the Black Country authorities, is to divide up contributions based on the proportion of historic net migration flows between the contributing authority and shortfall authorities.” (Para 4.6, Wolverhampton Local Plan - Regulation 19 Consultation Cabinet Report 13th November 2024) (Emphasis Added) 2.52 Importantly, Lichfields’ approach (i.e. Functional Relationship) aligns broadly with the BCA’s approach to apportioning proposed unmet need contributions to the BCAs as a whole. This approach also aligns in principle with the approach adopted to distribute Coventry’s unmet needs across the C&WHMA previously. Again, the Inspector for the Stratford-on-Avon Core Strategy (2017) endorsed this approach. More recently, in considering how the unmet housing needs of Leicester could be addressed throughout the Leicester and Leicestershire Housing Market Area [LLHMA] a similar functional relationship approach was utilised and has been accepted by Inspectors at the Charnwood EiP. 2.53 Notably, Lichfields analysis takes account of the degree of migration and commuting linkages within the GBBCHMA to the BCAs, opportunities to capitalise on sustainable transport links and improve affordability, and the degree of environmental and physical constraints which might impede on an authority’s ability to accommodate unmet housing need. The analysis ultimately illustrates the functional linkages between the authorities within the GBBCHMA, and the origins of the unmet housing need (i.e. the BCAs), and shows how the BCA’s unmet housing needs could be sustainably distributed. For SOADC, Lichfields’ functional housing market relationship analysis indicates that the SOADC should be seeking to make provision for c.1% of the total unmet needs of the BCAs – or around c.500 dwellings based on the current level of unmet need. 2.54 The above serves to highlight that there is evidence to suggest that the SWAs should be seeking to make an appropriate contribution through the SWLP now, rather than deferring it, in accordance with paragraph 35c of the NPPF. St Philips considers that given the relatively modest contribution required of SOADC when compared to the SWA’s own housing requirement up to 2050, it would be entirely reasonable and sustainable for the SWLP to make provision for this within the SWLP. St Philips considers that it is likely that there are sites throughout the SWLP area that could sustainably contribute to addressing the SWA’s own housing needs and a proportion of the GBBCHMA’s unmet housing needs. Indeed, it is evident that there are opportunities to allocate ‘suitable, available and achievable’ land and sites in sustainable locations across South Warwickshire.