Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifyi
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A trend based approach will direct too much development to South Warwickshire rather than to other areas of the Coventry and Warwickshire sub region where support and regeneration would be beneficial.
Yes - and there are different ways to assess housing numbers. Regardless of which of these are used, South Warwickshire requires a range of new homes of different types and tenure, in a range of geographical locations. The SWLP's approach to Spatial Growth is correct - it looks at how to provide for new homes, alongside all of the other things required for sustainable development. The SWLP must provide for certainty and focus on ensuring the delivery of beautiful homes as part of good planning. This requires grasping the nettle in respect of releasing land for development and instead of focusing too much on housing numbers, bringing the focus to delivering beautiful development that brings enhancement in the form of new market and affordable homes alongside all of the other ingredients necessary to deliver sustainable growth. The Henley-in-Arden Vision document provides an example of how this can be achieved.
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Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire and this approach is reasonable for other authorities in Coventry and Warwickshire. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals”. National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. On the basis of the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. In line with the NPPF, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness, which is explored in further detail in response to Issue H4 below. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, William Davis consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.
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The population growth analysis has been conducted too close to the emergence from the Covid-19 pandemic to generate reliable projections. It should be revisited to provide a better understanding of emerging trends. Following that it should be used in the correct order of process, to inform decision-making rather than being published afterwards to retrospectively justify decisions. Crucially, housing need should just be a “starting point” and local councils should work with their communities to determine an appropriate level. As the Secretary of State for Levelling Up said in his written statement (6.12.22): “It will be up to local authorities, working with their communities, to determine how many homes can actually be built, taking into account what should be protected in each area - be that our precious Green Belt or national parks, the character or an area, or heritage assets. It will also be up to them to increase the proportion of affordable housing if they wish.”
The issues with the 2014-based household projections have been known for a long as having over estimated the population growth level across the country. Despite this the NPPF still currently states that these are the figures which should be used. Within Warwickshire the biggest impact this has had is in Coventry where the highest levels of growth were taking place. Both Stratford and Warwick have been meeting their HDT and have delivered well in excess of 100% of their delivery requirements in 2021 and 2020. This together with the fact that both authorities have in excess of a 5 year housing land supply with the 5% buffer built in, all demonstrates that the authorities have been meeting their plan objectives by delivering dwellings in the past and there is no reason to doubt they will in the future. Looking at the trend based approach for Warwick and Stratford, these figures are in fact higher than the 2014-based projections. The 2014-based projections provides a requirement of 564 dwellings for Stratford and 675 for Warwick and the trend based projections set out a requirement of 868 for Stratford and 811 for Warwick annually. We note that the Urban Capacity study has a housing figure of 31,000, which is more in line with the 2014-based household projections. The conclusion from this was that to meet this lower overall number there would have to be development outside of the urban and settlement boundaries. If we agree that the trend based number are the most appropriate to use for the Plan period then the need to develop outside of the urban boundaries and the settlement boundaries has further increased. This is just the housing need for South Warwickshire; this doesn’t take into account needing to take on any unmet need from Birmingham and the Black Country. Stratford DC is part of the Birmingham HMA so would have been required to take some proportion of the unmet housing needs. If we use the trend-based figures then the housing need is 41,785 dwellings over the plan period; so annually this would be 1,672 dwellings per annum, as a minimum. Until it is clear what additional housing numbers are required from Birmingham and the Black Country, in South Warwickshire, the Plan needs to identify a range of sites which can realistically come forward, both adjoining all existing settlements as well as creating new settlements and providing the larger numbers as a minimum which the trend-based figures are suggesting. From the data on the tenure and type of housing required the greatest need for affordable housing is in South Warwickshire. The analysis indicates that the need for social or affordable rented properties should be focused on smaller properties, as in this sector households’ size is more closely aligned to the sizes of homes. 70% of the need identified is for 1- and 2-bed properties; and 30% for properties with three or more bedrooms. The greatest need for affordable home ownership is for 2 bedroom houses, with some need for 3 beds as well (for both Warwick and Stratford the need was 45% for 2 beds and 25% for three beds). Smaller scale sites can also help provide small scale affordable housing needs in settlements, and having varied affordable housing requirements across the SWLP area allows sites to be come forward and provide these units.
The population growth analysis has been conducted too close to the emergence from the Covid-19 pandemic to generate reliable projections. It should be revisited to provide a better understanding of emerging trends. Following that it should be used in the correct order of process to inform decision rather than being published afterwards to retrospectively justify decisions which it currently fails to do appropriately.
The HEDNA may well be an indicator of overall requirements. However the huge swing of demand away from Coventry and the North towards Rugby and the South must raise questions on its reliability unless backed by further evidence. Other environmental factors that support the Vision Statements and Strategic Objectives must be applied otherwise the calculation becomes too narrow. [The remainder of this response appears to relate to the Sustainability Appraisal rather than the HEDNA. As such it has been moved to the relevant question.]
The provision of a sufficient level of housing growth in the SWLP is required in national planning policy, specifically NPPF11(a) and (b). The SWLP Issues and Options is informed by the Coventry and Warwickshire Housing and Economic Development Needs Assessment (‘the HEDNA’, November 2022). This identifies a need for 868dpa for Stratford District and 811dpa for Warwick District, equating to 1,679dpa for the SWLP area. Over the 28-year plan period to 2050 this is a requirement for 47,012 dwellings. Nevertheless, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national policy and guidance (NPPF61 and NPPG010 - Reference ID 2a-010-20201216). Further consideration will also need to be given to unmet needs of neighbouring authorities in line with the Duty to Cooperate and the positively prepared test of soundness (NPPF35a). We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Coventry and Warwickshire; and Greater Birmingham and Black Country.
The provision of a sufficient level of housing growth in the SWLP is required in national planning policy, specifically NPPF11(a) and (b). The SWLP Issues and Options is informed by the Coventry and Warwickshire Housing and Economic Development Needs Assessment (‘the HEDNA’, November 2022). This identifies a need for 868dpa for Stratford District and 811dpa for Warwick District, equating to 1,679dpa for the SWLP area. Over the 28-year plan period to 2050 this is a requirement for 47,012 dwellings. Nevertheless, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national policy and guidance (NPPF61 and NPPG010 - Reference ID 2a-010-20201216). Further consideration will also need to be given to unmet needs of neighbouring authorities in line with the Duty to Cooperate and the positively prepared test of soundness (NPPF35a). We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Coventry and Warwickshire; and Greater Birmingham and Black Country.
The issues with the 2014-based household projections have been known for a long as having overestimated the population growth level across the country. Despite this the NPPF still currently states that these are the figures which should be used. Within Warwickshire the biggest impact this has had is in Coventry where the highest levels of growth were taking place. Both Stratford and Warwick have been meeting their HDT and have delivered well in excess of 100% of their delivery requirements in 2021 and 2020. This together with the fact that both authorities have in excess of a 5 year housing land supply with the 5% buffer built in, all demonstrates that the authorities have been meeting their plan objectives by delivering dwellings in the past and there is no reason to doubt they will in the future. Looking at the trend based approach for Warwick and Stratford, these figures are in fact higher than the 2014-based projections. The 2014-based projections provides a requirement of 564 dwellings for Stratford and 675 for Warwick and the trend based projections set out a requirement of 868 for Stratford and 811 for Warwick annually. We note that the Urban Capacity study has a housing figure of 31,000, which is more in line with the 2014-based household projections. The conclusion from this study was that, to meet this lower overall numbers, there would have to be development outside of the established urban/settlement boundaries. If we are agreed that the trend based numbers are the most appropriate to use for the Plan period, then the need to develop outside of the urban and settlement boundaries has further increased. This is just the housing need for South Warwickshire; this doesn’t take into account needing to take on any unmet need from Birmingham and the Black Country. Stratford is part of the Birmingham HMA so would need to take some proportion of the unmet housing needs. If we use the trend based figures then the housing need is 41,785 dwellings over the plan period; so annually this would be 1,672 dwellings per annum, as a minimum. Until it is clear what additional housing numbers are required from Birmingham and the Black Country, in South Warwickshire, the Plan needs to identify a range of sites which can realistically come forward, both adjoining all existing settlements as well as creating new settlements and providing the larger numbers as a minimum which the trend-based figures are suggesting. Form the data on the tenure and type of housing required the greatest need for affordable housing is in South Warwickshire. The analysis indicates that the need for social or affordable rented properties should be focused on smaller properties, as in this sector households’ size is more closely aligned to the sizes of homes. 70% of the need identified is for 1- and 2-bed properties; and 30% for properties with three or more bedrooms. The greatest need for affordable home ownership is for 2 bedroom houses, with some need for 3 beds as well (for both Warwick and Stratford the need was 45% for 2 beds and 25% for three beds). The larger strategic sites as well as the new settlements provide the best opportunity for the provision of affordable housing across the SWLP area.
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BGPC believes that any review of Green Belt boundaries should include changed circumstances that now justify land previously removed being returned to the Green Belt. A very good example is the land south of Westwood Heath Road (included in option C-17) between Bockendon Road/Crackley Lane and Warwick University. This was taken from the Green Belt in the revised Warwick Local Plan 2017 to be instead denoted as ‘safeguarded’ for future development (perhaps 700 - 900 homes) arising from Coventry’s alleged failure to have sufficient land to cope with population growth projections. These projections were hopelessly excessive, as confirmed by the 2021 Census results published last summer. In BGPC’s view this ‘safeguarded’ land should now be returned to the Green Belt to ensure an adequate divide between Coventry (north of Westwood Heath Road and the University at Gibbet Hill Road) and Burton Green’s NDP Development Area which ends at Crackley Lane as a result the granting of permission for 425 homes, now under construction between Westwood Heath Road and Bockendon Grange and which will double the size of Burton Green as it was in 2017. If the ‘safeguarded’ land were to be developed in the new SWLP it would result in a quadrupling of the size of Burton Green since 2017, whereas returning the ‘safeguarded’ land to the Green Belt would prevent continued urban sprawl between Coventry and Burton Green that local residents are genuinely concerned about.
The trend-based approach as set out in Table 9 is 648 dwellings less, compared to the 2014-based projection overall across the Housing Market Area. However, Warwick District, along with Stratford on Avon, are likely to see higher levels of growth which is encouraging. Paragraph 61 of the NPPF 2021 sets out that “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.” Paragraph 66 goes on “Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.” Under Annex 2 of the NPPF, local housing need Is defined as “The number of homes identified as being needed through the application of the standard method set out in national planning guidance.” To ensure continued growth and prosperity across the plan area, and to ensure the plan is found sound, housing need must be based on the recommendations set out in the NPPF. We are supportive of the fact that both Stratford-on-Avon and Warwick Districts are likely to see higher levels of growth.
2.1 Issue H1 of the Consultation Document sets out the SWLP approach to addressing housing needs across the plan area. It recognises in the first paragraph that England is experiencing a housing crisis and that planning and Local Plans are an important tool for addressing the crisis. This recognition is welcomed. 2.2 The Consultation Document goes on to set out that local housing need for South Warwickshire has been assessed in a Housing and Economic Development Needs Assessment (HEDNA). 2.3 The HEDNA has been prepared on behalf of all the Warwickshire districts plus Coventry and therefore presents a comprehensive approach to the calculation of need for the wider area. The NPPF 2021 is clear that local plans should assess local housing needs using the standard methodology for assessing local housing needs as a starting point, and should only deviate from using the standard methodology in ‘exceptional circumstances’. Furthermore, the NPPF 2021 sets out that any alternative method of calculating housing need must reflect current and future demographic trends (including migration) and market signals. 2.4 The HEDNA sets out that across Coventry and Warwickshire there have been historic problems with establishing population change in Coventry since 2001, and that these issues have been acknowledged by the ONS and the Statistics Regulator. The problems have led to significant over-estimates of population growth in Coventry which have in turn led to projections of population and housing growth which have been in excess of what has actually been needed. The latest results of the 2021 Census issued in June 2022 have again confirmed the existence of these issues. 2.5 The problems represent an exceptional circumstance that justifies moving away from the Standard Methodology. The HEDNA therefore proposes using alternative projections of household growth instead of the 2014 based Household Projections required by the Standard Methodology. These revised projections lead to a reduced local housing need for Coventry and Warwickshire of 4,906 new homes a year – down from 5,554 homes a year calculated using the Standard Methodology. The local housing need based on the new demographic projections is therefore 88% of the figure suggested using the Standard Methodology. 2.6 This headline figure masks changes within the constituent districts. With regard to Stratford-on-Avon and Warwick Districts, the new approach set out in the HEDNA results in significant increases in housing need – from 564 dpa to 868 dpa in Stratford-on-Avon, and from 675 dpa to 811 dpa in Warwick. In terms of the SWLP, the change from the Standard Methodology leads to an increase in housing need of 440 homes to be delivered each year. 2.7 We consider that this analysis set out in the HEDNA does represent a reasonable basis for identifying local housing need for South Warwickshire. It is helpful that the HEDNA undertakes the analysis across Warwickshire, and therefore picks up on demographic relationships that stretch across local government boundaries. This aspect of the analysis means that the assessment of need has greater legitimacy. It is also noted that the pattern of housing need falling dramatically in Coventry and rising in more rural areas matches national trends which have been seen strongly since the pandemic, but which existed prior to then and which reflect wider demographic changes. 2.8 Additionally, the Stratford-on-Avon Core Strategy sets out in Policy CS.16 a housing requirement of 14,600 new homes to be provided between 2011 and 2031 – an annual requirement of 730 dwellings a year. Clearly, this requirement is already significantly higher than the housing need suggested by the standard methodology. Stratford-on-Avon also reports a 5 year housing land supply position of 10.2 years’ supply of deliverable land for housing, and a housing delivery test result showing it has delivered 240% of its requirement (therefore over twice the level of new homes expected measured against the standard methodology). It seems very likely that Stratford-on-Avon district alone is more than capable of delivering new homes at the level suggested by the alternative method set out in the HEDNA, if not somewhat higher. 2.9 We therefore support the approach being suggested in the Consultation Document, but make the following points: a. In many respects, the assessment of housing need clarifies a position that has been apparent in policy – which is that Coventry is unable to meet its needs in full within its boundaries, and therefore neighbouring authorities within its HMA are asked to meet its unmet need and to agree a position through the Duty to Cooperate. The new assessment, by reducing Coventry’s need but increasing needs in some rural districts, simply makes the position clear in a demographic analysis. If a decision were made to revert to the Standard Methodology calculation, that decision would clearly need to made across Warwickshire and would have to include Coventry. The higher levels of need in Coventry would again lead to a significant level of unmet need, some of which would need to be accommodated in the SWLP area. It would therefore be likely that similar levels of need would be established in any case. Using the alternative local housing need methodology makes the situation clearer and easier to plan for and should be commended. b. It is noted, however that the establishment of a housing need figure for the SWLP is simply the first step in establishing a housing requirement to be met by the local plan. The Consultation Document does not set out a housing requirement for South Warwickshire, simply stating that the levels of need do not include an assessment of whether those levels of need can be met by a local authority. This assessment will be an important step to be taken and the results set out in the next iteration of the SWLP, but we would note that if the Councils were to set out a position suggesting that they were unable to meet the need now clearly set out in the HEDNA, it would be necessary to set out why that need could not be accommodated (including looking at all potential strategies for distributing need across the plan area and all potential sites for meeting that need) and also to show where any unmet need would then be met. We would suggest that the level of need is capable of being met within the SWLP area and that there are suitable sites available and deliverable to contribute to meeting that need, such as the land at Rogers Lane, Ettington.
Neither the previous approach nor HEDNA is appropriate. The policy should be driven by sustainability and environmental protection.
The HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals” . National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. Based on the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. In line with the NPPF , it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance ; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. Further consideration will also need to be given to unmet needs within the Housing Market Area.
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1. Remove impact of past Coventry/Birmingham overspill on recent new housing completions and approvals to avoid artificial inflation of 'local' trends 2. Remove Coventry and any other overspill from the numbers as a starting point for future trends 3. Recognise that the historic model of delivering the needs for affordable and especially social rented housing has failed, as clearly shown in the draft HEDNAA. Therefore, drastically change the standard methodology model and concentrate it on direct provision of those needs, either by local authorities with housing associations or as a much higher % of market housing eg 70%. 4. Recognise that the climate emergency must have priority alongside this urgent need for affordable housing and that this will severely limit the construction resources of skilled staff and finance available for market housing over the next 10 years. Devise plan which includes major retrofitting of existing housing/building stock to achieve drastic cuts in regional emissions. (The last two priorities will require much innovation - for example in incentives, training, additional borrowing, higher LA and collaborative investment, perhaps greater use of CPO, stronger intensification standards and enhanced residential design guides, amongst other policy adjustments).
As mentioned above the population growth analysis has been conducted too close to the emergence from the Covid-19 pandemic. It should be revisited to provide a better understanding of emerging trends. Following that it should be used in the correct order of process, to inform decision-making rather than being published afterwards to retrospectively justify decisions. Crucially, housing need should just be a “starting point” and local councils should work with their communities to determine an appropriate level. As stated by the Secretary of State for Levelling Up (see above). “It will be up to local authorities, working with their communities, to determine how many homes can actually be built, taking into account what should be protected in each area - be that our precious Green Belt or national parks, the character or an area, or heritage assets. It will also be up to them to increase the proportion of affordable housing if they wish.”
Too little is known about population growth and economic developments following the pandemic to make forecasted trends reliable. At this stage they are probably guesswork.
Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Rosconn Strategic Land reserve its position in respect of whether this approach is reasonable for other authorities in Coventry and Warwickshire. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals” . National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. On the basis of the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. In line with the NPPF , it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance ; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness , which is explored in further detail in response to Issue H4 below. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, Rosconn Strategic Land consider that the SWLP will need to plan for a level of housing growth as set out in the below Table in the order of at least 43,000 dwellings.
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I have no idea what this is. Housing development favours those with large families and this is contradictory to true sustainability