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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Since the start of 2020, the UK has formally left the EU and the world has experienced a pandemic. These events are unprecedented, and the impact is still being realised. Since the start of the pandemic many aspects of our daily lives, particularly work, have significantly changed. Trend analysis may not be accurate as we now settle into a post-pandemic society that is outside of the EU. The pandemic led some to move to a more rural location, however, this may not continue as the limitations of rural life become more apparent.
Issue H1. Providing the right number of homes. In the absence of a regional, sub-regional or strategic approach to determining housing levels, we are left with the untidy system of calculating housing numbers by Districts (or combinations of Districts), based on demographic, economic and social measures of housing need. As the introduction to this section acknowledges, there is a growing housing crisis in Britain. Government and local authorities are quite deliberately failing to reach the aspiration of 300,000 dwellings per year. The most recent planning reform proposals (influenced by a minority of backbench MP’s) will exacerbate this still further by substantially reducing housing provision especially in the areas where housing is most in demand, for example in London and the south-east. Furthermore, it is misleading and naïve to suggest (as stated on page 100) that the key issue is simply about providing ‘affordable homes’ and that building lots of ‘unaffordable’ market homes is not the solution. In truth, no market houses are ‘unaffordable’ – if they were, they would not be bought and occupied. In practice, Stratford and Warwick Districts are both high value areas and hence house prices reflect those sales values. Subsidised housing, if it is built, either has to be delivered through cross subsidy (from market housing) or paid for through grant aid. The price levels are influenced by the past housing shortfall. Hence it is logical that Stratford and Warwick should allocate higher levels of housing to deliver for both market and affordable occupiers as well as helping to moderate price levels. The sub-regional figure is relevant but is distorted by the influence of Coventry City where past allocations have been capacity-based and have aimed to focus as much housing as possible within the City (this has then resulted in a backlash when Coventry’s green belt boundaries have been reviewed as a consequence). Stratford and Warwick should therefore accommodate a higher share of housing provision to meet the trend-based figure. The precise level will evolve from the discussions emanating from the Duty to Co-operate and the outcome of the HEDNA.
Don’t Know. Paragraph 61 of the National Planning Policy Framework (NPPF) requires the ‘standard method’ to be used for calculating housing need unless ‘exceptional circumstances’ justify an alternative approach. It is not clear if the justification for the proposed alternative approach constitutes exceptional circumstances. We are pleased to see the acknowledgment, in the Issues and Options consultation document, that the standard method and HEDNA figures do not reflect any assessment of whether those needs can be met within each local authority area. In this context, it is important to note paragraph 11b and footnote 6 of the NPPF, which identifies certain exemptions to the requirement to meet the following needs through the plan-making process: (i) objectively assessed needs; and (ii) needs that cannot be met within neighbouring areas. In other words, there are circumstances in which the housing requirement figure (i.e., the amount of housing that should be provided for once relevant constraints have been factored in) could potentially be less than the housing need figure (i.e., the unconstrained assessment of housing need). This is expanded on in the Government’s ‘Natural Environment’ planning practice guidance, which states that: . The NPPF’s policies for protecting Areas of Outstanding Natural Beauty (AONBs) ‘may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process’; and . AONBs ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’.17 For the second of these points, we interpret this to relate to both: (i) unmet needs arising from neighbouring local authority areas; and (ii) unmet needs arising within the local authority area but outside of the Cotswolds National Landscape. These points should be factored in when considering an alternative approach to the ‘standard method’ and / or when determining the housing requirements for the area and the spatial distribution of this housing. 17 https://www.gov.uk/guidance/natural-environment#landscape. Paragraph 041 Reference ID: 8-041-20190721
Issue H1: Providing the right number of new homes: I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
Yes the HEDNA appears to provide a reasoned basis for departing from the Standard Method based on the 2014 household projections and we have no objection to using a trend based approach as is suggested as it is fully justified and explained. It provides a useful starting point for identifying future levels of housing need across South Warwickshire.
Issue H1: Providing the right number of new homes - QH1-1 - The HEDNA appears to provide a reasoned and appropriate basis for departing from the Standard Method approach and use of the 2014 household projections. It provides a useful starting point for identifying future levels of housing need across South Warwickshire. - Beyond the HEDNA it is then of course necessary for the LPA to then consider the unmet need of neighbouring authorities and plan positively to meet wider needs.
I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
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3. Delivering Homes to meet the needs of all of our communities : Question H 1.1 The evidence base concludes that Stratford-on-Avon and Warwick are the least affordable areas in the Coventry and Warwickshire sub-area and it important therefore that the Strategy focuses growth both within these towns and in locations which are close to and easily accessible to these towns – including Long Marston. The affordability crisis will be further exacerbated if the Local Plan provides too few houses, either by a policy choice not to meet the objectively assessed level of housing need, or by adopting a housing strategy that cannot deliver sufficient housing to meet the needs. Relying on the delivery of new “new settlements” could result in such a risk to the overall strategy. The consultation document notes that “whilst it may be tempting to want to apply the 2014-based figures because they are lower for South Warwickshire, given that Coventry looks unable to accommodate all of its own housing needs, it would most likely fall to South Warwickshire to accommodate a significant quantum of that need. The outcome would then most likely be similar levels of housing as shown in the 10-year trend-based projection”. It would be wrong therefore to adopt a Local Plan that was not based on the scale of housing which is adjusted to accommodate neighbouring need. And on this basis, the housing requirement should be the higher of the two suggested figures. Based on the evidence of potential existing housing supply in the Urban Capacity study this would suggest a residual need for some 22,000 new homes to be provided over the plan period.
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In accordance with Table 9 (Overall Housing Need in Coventry and Warwickshire (dwellings per annum) of the South Warwickshire Local Plan Part 1 (Stage 2: Issues and Options Consultation, January 2023), the 2014-based projection results in a housing need of 1,239 per annum for Stratfordon-Avon and Warwick. The trend-based approach results in an increased housing need of 1,679 per annum. It’s important to note that for all other Local Authorities in Coventry and Warwickshire, the trend-based projection results in a lower housing need, with the exception of Rugby. Paragraph 61 of the NPPF (2021) is clear that to determine the local housing need, the standard method must be used unless ‘exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals’. This is reiterated in paragraph 003 of Planning Practice Guidance relating to Housing and Economic Development Needs Assessments which reads as follows; ‘there is an expectation that the standard method will be used and that any other method will be used only in exceptional circumstances.’ The first step to calculating housing need in the Planning Practice Guidance is setting the baseline using the national 2014-based household projection rather than a trend-based approach. The Coventry & Warwickshire Housing and Economic Development Needs Assessment (HEDNA) (November 2022) states that ‘population growth for Coventry appears to be systematically overestimated, which leads to trend-based projections that are demonstrably too high. Additionally, there is evidence that more recent trends in population growth (confirmed by Census data) in many parts of Warwickshire have been stronger than in the period to 2014 – mainly due to changes in migration levels – and so the 2014-based figures can be thought of as unreliable. It is also the case that other key aspects of population projections (fertility and mortality rates) have diverged significantly from those projected in the 2014-based projections.’ Paragraph 015 of Planning Practice Guidance relating to Housing and Economic Development Needs Assessments states that ‘where an alternative approach results in a lower housing need figure than that identified using the standard method, the strategic policy-making authority will need to demonstrate, using robust evidence, that the figure is based on realistic assumptions of demographic growth and that there are exceptional local circumstances that justify deviating from the standard method. This will be tested at examination.’ Thus, whilst we have not scrutinised the data and evidence underpinning the proposed trend-based approach, in our view proceeding with the alternative approach presents a risk of significant scrutiny during examination testing. In any event, the objectively assessed housing need is a minimum starting point. As detailed in paragraph 10 of Planning Practice Guidance relating to housing and economic needs assessment, the objectively assessed housing need is ‘a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour.’ It is also strongly recommended that South Warwickshire include a further economic uplift to facilitate growth and support the community in the economic recovery. The economic benefits of delivering housing and its contribution to building a strong and competitive economy in line with paragraph 8 of the NPPF (2021) is well established. The Economic Footprint of UK Housing Building in England and Wales (July 2018) prepared by the Home Builders Federation and Lichfields states that £39bn is generated as an economic output as a result of house building each year. This financial output can also result in a positive impact on the environmental and social objectives outlined in national planning policies. As detailed in our response to Q-H2-1, South Warwickshire have a significant need for affordable housing. Chapter 6 of the South Warwickshire Local Plan Part 1 (Stage 2: Issues and Options Consultation, January 2023) is clear that affordable homes are primarily delivered as a percentage of market housing schemes. Thus, in order to significantly boost the supply of affordable homes to meet the needs of the local community, a further uplift to the assessed housing need is required. As detailed in our response to Q-H4-1, Q-H4-2 and Q-H4-3, an uplift is also required to meet the needs of neighbouring Authorities in accordance with the duty to cooperate and the test of soundness.
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2.30 Response: In so far as there is some balance between employment land requirements and housing provision, the public interest is better served by an over-provision of employment land than an under-provision because local development plans are insufficiently agile to release further land in order to accommodate employment needs. The Local Plan should include a policy that allows for additional land to be released for employment purposes in circumstances where it can be demonstrated that existing employment site are either not suitable or not available to meet employment requirements. 2.31 It is evident that some allocations in the current development plan have failed to deliver new employment development. The availability of such sites to contribute to the supply of employment land opportunities should be reviewed. No purpose is served in allocating land for employment development where the land is not then brought forward into development. The effective supply of industrial land is then over-estimated, which frustrates new investment and jobs. it would be inappropriate to envisage that existing employment sites are capable of producing new sources of land for investment. The joint Plan must allocate new land for employment development on the urban edge of the main settlements. The land must be suitable and attractive for new inward investment. 2.32 In so far as there is some balance between employment land requirements and housing provision, the public interest is better served by an over-provision of employment land than an under-provision because local development plans are insufficiently agile to release further land in order to accommodate employment needs. The Local Plan should include a policy that allows for additional land to be released for employment purposes in circumstances where it can be demonstrated that existing employment site are either not suitable or not available to meet employment requirements. 2.33 A criteria based policy would be appropriate to establish the need and suitability of additional land to meet employment needs.
Paragraph 61 of the Framework advises that in order to determine the minimum number of homes needed, strategic policies should be informed by local housing needs assessment, conducted using the Standard Method in National Planning Practice Guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing needs figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. We note that the Standard Method housing figures for Stratford-on-Avon and Warwick Districts are 564dpa and 675dpa respectively. The trend based projection in the HEDNA suggests that 868 dpa are required in Stratford-on-Avon and 811 dpa in Warwick District respectively. As the HEDNA figure is above the Standard Method housing requirement we have no particular concerns with the HEDNA methodology departing from the Standard Method as the level of development proposed would ensure that the minimum Standard Method housing requirement is exceeded. We note that this is not the case in the Coventry and Warwickshire plan area as a whole, where the total housing requirement in the HEDNA is less than the Standard Method requirement. This is principally due to the fact that the HEDNA suggests that the housing needs of Coventry is significantly below the Standard Method figure. We restrict our comments to the Stratford-on-Avon and Warwick sections of the HEDNA only and do not seek to comment on the Coventry figure at this stage given that it relates to a different plan area. In terms of the approach of the HEDNA, it is noted that Table 8.13 – Estimate Need for Social/Affordable Rented Housing by Local Authority, identifies a net need for 419 affordable dwellings per annum in Stratford-on-Avon and 582 affordable dwellings per annum in Warwick District. This equates to 67% and 52% of the identified overall housing requirement respectively for the two authorities. The PPG advises at paragraph 2a-024 that the total affordable housing need can be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered, if it would help to deliver the required number of affordable homes. In all likelihood, the principal way affordable housing will be delivered during the course of the plan period will be through planning obligations associated with residential developments. We are concerned that there will be a significant shortfall of affordable housing provision during the course of the plan period to meet their identified need, as is not realistic to expect housing allocations to deliver 67% or 52% affordable housing. There should, therefore, be consideration to uplift the housing requirement to ensure that an appropriate amount of affordable housing is met. This is particularly important given that the plan advises that the issue of housing under-supply is “specifically and crucially . . . . an issue to do with the lack of affordable housing supply”. There are other documents that support an uplift to the SWDP’s housing requirement to assist with affordable housing delivery. The Stratford-upon-Avon District Housing Strategy (2021 – 2026) sets out three aims including supporting communities and building sustainable and affordable homes. The Warwick District Council Housing Strategy (2014 – 17) sets an objective of meeting the need for housing across the district. The Draft Plan advises at page 98 that there is an issue with affordability, with individuals with lower paid jobs being unable to afford to live within the plan area and having to commute from Coventry. A lack of housing land supply will increase house prices making this issue more profound. The draft Plan also recognises that providing new homes will support the local economy, through the creation of construction jobs and help ensure that existing facilities and services remain open by increasing footfall. All current evidence suggests that the housing requirement should be adjusted upwards from the HEDNA figure to support affordable housing delivery. This would support the Social Role of sustainable development identified by the NPPF, by ensuring that a sufficient number and range of homes are provided to meet the needs of present and future generations.
Overall comments on the HEDNA Much of this analysis is based on the assumption that we move away from the 2014 analysis of household projections and adopt the HEDNA (https://www.southwarwickshire.org.uk/swlp/technical-evidence.cfm). We don’t feel enough evidence for the South Warwickshire Plan has been provided to make an informed decision on the validity of the HEDNA analysis. There are several points of confusion: 1. You state that “Coventry and Warwickshire can be regarded as a coherent housing market area,…… albeit that that there are differences in the economic characteristics between the north and the south of the area” We would say the differences have been under emphasised. 2. We are not sure why an analysis which includes Coventry is being so heavily relied upon to make housing projections for south Warwickshire. 3. One of your most compelling reasons for adopting the HEDNA approach rests on the belief that the 2014 analysis significantly over estimated population projections for Coventry. This may well be true but your figures then increase projections for Stratford and Warwick Districts. It is not completely clear what the justification for this is.