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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It is still does not properly model the size and characteristics of the massive student populations. Many students do not stay in the sub-region after graduation and ONS have been very poor at modelling this. Students also are likely to have less children and have them later than the average young adult. The growth in students is also limited by the total pool of young people and economic factors. For the next few years the numbers may rise but will then be impacted by the sharp fall in UK birth rates after 2010. The HEDHA also does not seem to model what is going on with older people. We are seeing life expectancy improvements stall and in some places reverse. The post war and 1960’s baby booms are also key factors in modelling changes in mortality, needs for specialist housing and stagnation in size of working age population. From preliminary monthly mortality data we can see deaths in the Sub-region have gone from around 7,600 a year in 2012 to 8,300 in 2017 to 9,300 in 2022. The Sub-region already has around 13,000 homes sitting empty and considerable that are massively under-occupied. That is up from around 8,000 a decade ago. The HEDNA ignored this and seems to assume we will be building far more dwellings than the rise in households. Thirdly the HEDHA does not take account of the end of near zero interest rates and the impacts of BREXIT, conflicts and climate change. Cheap money lead to massive house price inflation, house building and pricing many out of the market. We are now seeing the shrinking of UK industries such as car making and the start of a crash in house prices. We are possibly going to see lower level of migration and a greater need to refurbish existing housing stock. Natural population change will be near zero or negative and the nature of migration will change.
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The basis for the proposed housing numbers is the 341 page report: “Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA)” found at https://www.southwarwickshire.org.uk/doc/211518/name/CW%20HEDNA%20Final%20Report%20171122%20Clean%20.pdf Chapter 5 describes the ‘standard method’ for calculating required housing numbers: 1. Previous rate of building houses. 2. Increase the rate depending on the affordability ratio (median house price divided by median salary) 3. Impose a cap if necessary (not applicable locally), and 4. Increase the rate for large urban centres (applies to Coventry). Therefore, it requires faster and faster housebuilding locally. There are several contentious issues here. The government expects 2014-based Household Projections to be used, whereas the report sensibly indicates that the 2021 census is more accurate and recent. Using the census figures would require higher housebuilding in south Warwickshire but lower building in Coventry and north Warwickshire. However, this doesn’t adjust for the fact that Warwick District’s current local plan already includes 5,976 over-spill homes for Coventry, which the census shows were based on grossly inflated claims regarding population growth in Coventry. Therefore, it could be argued that both the 2014 and census figures are too high for Warwick District. The government’s formula requires exponential increases in housebuilding which are clearly unsustainable both environmentally and socially. The affordability ratio is based on single incomes, whereas many properties are bought by couples who are both working. No adjustment is made for inherited wealth (and the bank of mum & dad), which is increasingly important for house purchases. Thus, the government's bizarre self-reinforcing calculations are not evidence based, do not reflect how people finance house purchases, and make no effort to address regional issues.To tackle the housing crisis, the government needs to reduce the wealth gap in society and regional variations rather than building more houses, particularly in hot spots like south Warwickshire, that are unaffordable for too many. One of the factors of the overheated housing market is investors buying additional properties to rent meaning that there are fewer available for people wanting to own their own home. For these people the properties exist, but are unaffordable. The Council should take a stronger line on enforcing higher standards for landlords, so that not only do tenants have good properties, but that other investments will yield a higher return leaving more properties for people aspiring to own their own home. Regarding the number of houses to be built, the government has recently announced “This number should, however, be an advisory starting point, a guide that is not mandatory.” Unfortunately, it is unclear how far a local plan can deviate from this number nor what justifications are required. At the same time, it was announced that it was “ending the so-called ‘duty to co-operate'” which implies that Warwick District will not be required to take any future Coventry over-spill. Given the current chaotic, uncertain and illogical regulatory environment, it is extremely difficult to make rational decisions on housing numbers in the best interests of local residents. If it is assumed that the duty to cooperate has ended and that local plans no longer need to closely follow HEDNA numbers, it would be sensible to decide a number significantly lower than the 2014-based projections for Warwick district. This is because it is unclear of the impact of the enormous house building programme currently underway, particularly south of Leamington/ Warwick and from Kenilworth to Coventry. It may be that this, current economic uncertainty and other factors will reduce the affordability ratio and slow the demand for further housing.
Q-H1-1:• The HEDNA is absolutely right to move away from the Standard Method recommended by the Government. As the ONS acknowledges, the Standard Method used to project population growth has consistently over estimated growth in Coventry. • The HEDNA report, however, acknowledges that providing an accurate assessment is challenging for Coventry population growth, which throws up inconsistencies and discrepancies, resulting in over estimation of the projected population. • With this very uncertain base, can we have any confidence in the population projections for 2029 – 2050, from which housing need is derived. To that end para 5.109, page 136 of the final report acknowledges that assumptions will need to be reviewed – “needing to grapple with the same issues raised, notably how to deal with past population estimates where Census data shows these to be substantially wrong.” • The Standard Method took 2014 based household projections (it is not apparent how firm a base point this was) and applied an uplift, based on relative affordability in the area. For the Coventry area, the report advises that a 35% uplift was applied and from these assumptions and calculations, a figure of 5,554 dwellings is arrived at as the required number of new dwellings per annum in the Coventry and Warwickshire area. Para 15.3 explains that new demographic projections have been used and the result is a projected need of 4,906 dwellings per annum. There is little indication that there is any more reliable evidence to support the revised housing number. • Given these significant uncertainties and given that there is six years before the plan period commences and twenty seven years until it ends, we do not think that you have a base for making any definitive projections for housing needs. Q-H1-2:• We have no expertise in assessing housing needs but it would seem that the first priority would be to review the assumptions made by the Standard Method in assessing past population growth, determine where reality differed from the assumptions and seek to adopt more appropriate assumptions for the future.
It is key that windfall sites are taken into consideration in any plan. Since 2011, use of these sites has provided enough land to satisfy housing needs without appropriating what is currently green field/farm land. Once farm land is used, it’s gone and it’s development is difficult to reverse. A key focus on effective use of brownfield sites has to be a priority. In addition, what thought has been given to increasing housing in town centres? Is there an economic argument for assisting the redevelopment of empty shops (e.g. in the centre of Leamington) into housing? That appears to provide a double benefit since it will also increase footfall around remaining shops.
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The HEDNA proposal places too much emphasis on the 2021 Census without considering other explanations. It is recognized that both Coventry and Warwick District figures are affected by a significant student and university population. The 2021 Census ‘point’ took place against the backdrop of the 3rd national lockdown, and during the Easter break. It would therefore be expected that the population measured in the city of Coventry with two universities, might not be measured as high as other estimates arising from other data sources. Similarly, the populations of Warwick and Stratford might be higher than expected owing to students staying at family homes. Another influence might be associated with the progress of planning policies in the different authorities – it has been easier for developers to build in the non-Green Belt areas of Warwick and Stratford while for Coventry new homes require previously developed land or Green Belt. Indeed, the 2021/22 AMR for Coventry boasts that almost 50% of its new dwelling are purpose-built student accommodation! Consequently, part-way into the local plan cycles, new houses delivery is on course in Warwick and Stratford, whereas in Coventry the delivery of new houses for non-students is not. It’s probably best to use the standard government method, and if Coventry (or Birmingham) require room to grow, it should be on their fringes.
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It must be revisited on a year by year basis not just trends as they change if you don't keep your eye on them. It is utterly unacceptable that south Warwickshire needs to meet Coventry's unmet housing need because it forces people to live in South Warwickshire then commute to Coventry, clogging up the roads. Absolutely ridiculous and WDC needs to push back on this ludicrous situation rather than capitulating to it. It's absurd. Surely it should be up to those areas to come up with a solution rather than force more houses further and further away.
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This is set out in our attached report on Housing and Employment Need. The HEDNA approach relies on trend-based provision of future housing which are overwhelmingly the result of migration patterns into the SWLP area over the last decade and which have resulted in large part from faulty calculations of population and housing growth, particularly in Coventry. The result for the SWLP area can be seen in the table below. TABLE (See in CPRE's submitted report): ONS SNPP: Population Growth 2018-2028 (using 2018 MYE) Total: Warwick 9,451, Stratford 17,810 Natural change: Warwick 2,250 (births greater than deaths) Stratford -3,355 (deaths greater than births) Net inward migration: (UK and international) Warwick 7,218 Stratford 21,085 Net in-migration as a % of population growth: Warwick 76% Stratford 118%. This has led to a trend which works against sustainable development and which encourages higher housing need in more expensive areas around Coventry, leading to an undesirable loop,with further more in-migration.. The trend-based projections in the HEDNA would perpetuate this. Not only would they drastically increase housing provision in the SWLP area themselves, but there would be no guarantee that Coventry would adopt the lower figures in the HEDNA report. Indeed, that would, as it stands, be contrary to the NPPF, unless they could find exceptional circumstances to do so. Even if they did accept the HEDNA figures they would still be adding both the affordability add-on and 35% to their housing need. In all cases, if they then declared an unmet need based on inflated housing numbers, the SWLP area might end up with additional housing, both from its own approach and from a contradictory approach by Coventry. Given that both districts have extensive Green Belt and other constraints and given the aim of the Government to encourage urban regeneration, this seems a perverse outcome. The level of need is likely to be further exaggerated by the assumption in the HEDNA of a return to previous Household Representative Rates; that is to say in line with the ONS2014 figures. CPRE's submitted report explains that such a return to old HRRs should be regarded now as unrealistic and that many changes which have slowed down the historic trend of a reduction in household size are systemic. The Issues & Options says: ‘An added disadvantage of using the 2014-based projection would be that the South Warwickshire Local Plan was predicated on figures based on erroneous assumptions that have been proven to be wrong.’ However, it appears that despite this statement, the approach suggested would in fact perpetuate those past mistakes both technically and practically. Finally, the calculation in the HEDNA (and in the Plan) is based on the Standard Methodology which includes an affordability adjustment which is particularly high in the SWLP area because it is an attractive area but also because house prices rose significantly in 2021, so the adjustment may fall in the next few years. The Median House Price/Earnings Ratio for 2021 in Warwick is 10.73 and in Stratford 10.62, which in the SM case raises the requirement from 874 dpa raises to 1239 under ONS2014 adjustment, a 42% uplift on the need in the two districts. We also note that Table 9 refers to both the ONS2014 Standard Methodology requirement and the HEDNA trend-based calculations as measures of housing ‘need’. We consider this to be both incorrect and misleading. Both tables include an ‘affordability’ uplift and the 35% addition for Coventry. This is a table of ‘the requirement under the policy’ not ‘need’.
Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, HLM 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. As set out in the appended South Warwickshire Housing Need Evidence Base Review Technical Report commissioned by HLM, whilst HLM support the housing need figures for South Warwickshire set out in the HEDNA, HLM have some concerns with the approach taken in the HEDNA to economic growth and affordable housing need. On economic growth, whilst HLM agree with the demographic modelling assumptions used to calculate economic-led housing need in the HEDNA, the job growth assumptions require updating for the following reasons: - The 2022 HEDNA’s Cambridge Econometrics (CE) job forecast is outdated (March 2021) and was generated during strict Covid-19 measures in the UK; - CE are a robust source of job forecasts but a more recent forecast should be used; - Assumed GDP informing the HEDNA’s job growth forecasts has now been shown to be an underestimate of growth by the Office for National Statistics; - The higher GDP for 2021 and 2022 indicates job growth forecasts would be higher than those used by the HEDNA; - Furthermore, job growth experienced in Warwick District and Stratford-on-Avon District during 2011 to 2019 significantly exceeded the CE forecast used to calculate economic-led housing need for the 2022-2043 period; - It is unclear from the HEDNA whether economic growth on a number of sites within South Warwickshire are taken account of by the CE baseline projections. If not, these developments should be taken account of; - The Council should consider job growth forecasts from Oxford Economics and Experian Economics alongside those from the CE. HLM also consider that the significant level of unmet affordable housing needs across South Warwickshire should be taken into account in determining the housing requirement. The submitted analysis finds that the minimum housing need would be 1,609 dwellings per annum in Stratford-on-Avon District and 2,872 dwellings per annum to meet affordable housing needs based on past net delivery. Whilst it is recognised that this is significantly greater than the level of housing need set out in the HEDNA and is possibly unsustainable to deliver, this should influence the housing requirement through an appropriate uplift. The enclosed analysis should be given consideration as the SWLP emerges, to ensure a sufficient level of housing is planned for across South Warwickshire. 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, HLM 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 sources used to inform the HEDNA are clearly important, but the widest-ranging and most current data must be sought out and figures should be updated and reality-checked as the Local Plan process continues. More importantly, it needs to be recognised and remembered that the housing need figure is "only a starting point" (Michael Gove, 6th December 2022) and that the projected housing figure should take account of genuine constraints that exist. In the case of South Warwickshire, and in particular Warwick District, the Green Belt is a genuine constraint on development.
Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Richborough Estates 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. As set out in the appended South Warwickshire Housing Need Evidence Base Review Technical Report commissioned by Richborough Estates, whilst Richborough Estates support the housing need figures for South Warwickshire set out in the HEDNA, Richborough Estates have some concerns with the approach taken in the HEDNA to economic growth and affordable housing need. On economic growth, whilst Richborough Estates agree with the demographic modelling assumptions used to calculate economic-led housing need in the HEDNA, the job growth assumptions require updating for the following reasons: • The 2022 HEDNA’s Cambridge Econometrics (CE) job forecast is outdated (March 2021) and was generated during strict Covid-19 measures in the UK; • CE are a robust source of job forecasts but a more recent forecast should be used; • Assumed GDP informing the HEDNA’s job growth forecasts has now been shown to be an underestimate of growth by the Office for National Statistics; • The higher GDP for 2021 and 2022 indicates job growth forecasts would be higher than those used by the HEDNA; • Furthermore, job growth experienced in Warwick District and Stratford-on-Avon District during 2011 to 2019 significantly exceeded the CE forecast used to calculate economic-led housing need for the 2022-2043 period; • It is unclear from the HEDNA whether economic growth on a number of sites within South Warwickshire are taken account of by the CE baseline projections. If not, these developments should be taken account of; • The Council should consider job growth forecasts from Oxford Economics and Experian Economics alongside those from the CE. Richborough Estates also consider that the significant level of unmet affordable housing needs across South Warwickshire should be taken into account in determining the housing requirement. The submitted analysis finds that the minimum housing need would be 1,609 dwellings per annum in Stratford-on-Avon District and 2,872 dwellings per annum to meet affordable housing needs based on past net delivery. Whilst it is recognised that this is significantly greater than the level of housing need set out in the HEDNA and is possibly unsustainable to deliver, this should influence the housing requirement through an appropriate uplift. The enclosed analysis should be given consideration as the SWLP emerges, to ensure a sufficient level of housing is planned for across South Warwickshire. 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, Richborough Estates consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.
Not sure if any of these projections are reliable
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Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Countryside Properties 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, Countryside Properties consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.
Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Bloor Homes 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, Bloor Homes consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.
We should primarily take into consideration the fact that Warwick District’s current local plan already includes 5,976 over-spill homes for Coventry, which the census shows were based on grossly inflated claims regarding population growth in Coventry. Therefore, it could be argued that both the 2014 and census figures are too high for Warwick District.
Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Bloor Homes 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, Bloor Homes consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.
Yes, the HEDNA evidence does provide a reasonable basis for identifying future levels of housing need across South Warwickshire. The provision of a sufficient level of housing growth in the SWLP is critical, in accordance with the NPPF. SWLP Issues and Options consultation evidence base includes the Coventry and Warwickshire Housing and Economic Development Needs Assessment (‘the HEDNA’, November 2022). The HEDNA seeks to explore the housing and employment needs across Coventry and Warwickshire, and applies a trend-based approach to modelling housing need in order to establish the starting point for the respective Local Authorities in plan-making. The HEDNA applies the principles of the Standard Method calculation set out in national policy but utilises new demographic projections, supported by early data releases from the 2021 Census, to better reflect the needs of the respective and collective Local Authorities. The overall outcome for Coventry and Warwickshire is a decrease in annual housing need from 5,554 dwellings, derived from applying the Standard Method formula as set out in national policy, to 4,906 dwellings. Whilst there are decreases in annual housing need for some of the Local Authorities, and in particular Coventry (a considerable reduction from 3,188 dwellings per annum to 1,964 dwellings per annum), for South Warwickshire there is an overall increase. 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. Emerging Requirement and Capacity To summarise, MacMic Group consider that the basis for housing need in South Warwickshire should be the HENDA and that the Plan period should be assumed from 2022 onwards. As a result, MacMic Group consider the local housing need for the SWLP to be 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 ; 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 Q-H4-1 below. With regard to capacity, MacMic Group consider that there are 14,360 dwellings with planning permission at 1st April 2022 which can be included as supply, applying a 5% lapse rate to the number of dwellings set out in the respective Housing Trajectories. There are also a further 5,579 dwellings on outstanding Local Plan allocations without planning permission which can be included in the supply, however it should be ensure that such sites can still be considered to be Developable in line with the NPPF . With regard to any windfall allowance, this should be calculated on the basis of compelling evidence that it will provide a reliable source of supply, as required by the NPPF. Conclusion on Housing Requirement MacMic Group consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.