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
We note that the figures generated by the HEDNA for South Warwickshire are higher than the figures generated for the area by the Standard Method and the 2014-based household projections. Since a higher number is proposed for the area than the minimum suggested by the Standard Method, the question of whether to use the HEDNA or the Standard Method as far as the SWLP is concerned is largely academic, and we do not have any particular comments in this regard at the present time. We do, however, have broad comments about the general approach employed by the councils in this instance and the rationale for it as there are ramifications for the broader sub-region. The 2021 census data, as with household projection data post-dating 2014, suggests a lower housing need across England as a whole, hence the Standard Method for calculating housing need is still based on the 2014-based household projections as these fulfil the Government’s policy objective of delivering 300,000 homes annually. Rather than statistical rigor, this approach is about rectifying the housing crisis precipitated by drastically worsening affordability on a national basis, caused by decades of under-delivery. The Centre For Cities, for example, estimates that there is a backlog of approximately 4.3 million homes.1 We therefore regard the issues raised with the rigor of the Standard Method and its underpinning data to be largely trivial, technical points that do not undermine the validity of using the Standard Method generally, which is driven by the Government’s justifiable policy objective to build more houses. The above notwithstanding, the lower figures generated by the post-2014 household projections can be explained at least in part by lower household formation caused by a lack of housing availability. We acknowledge this is not the case across the board, however. For example, Lichfields states that the 2021 Census shows that despite Coventry have one of the highest rates of housing growth in the Midlands and the North between 2011 and 2021, its population growth was lower than expected which may support the argument that housing need in Coventry is over-stated. By that same token, Lichfields also states that Coventry remains one of the more affordable housing markets seeing only a modest worsening of its affordability ratio in the last decade, with a much lower increase in its affordability ratio than most of its neighbours.2 The conclusion to be drawn is that by “pulling up the drawbridge” and providing fewer homes than were previously anticipated across Warwickshire as a whole will result in worsening affordability, lower levels of homeownership and, potentially, suppressed population growth which will lead to more of the same. We do not consider this to be a desirable outcome.
2.43. Yes. Overall, the Respondent considers that the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, it should be noted that the level of future housing need stated in the HEDNA is a floor figure and does not include any unmet housing needs that may arise from other local authorities, which still needs to be established under the duty to cooperate. 2.44. In setting a housing requirement for the plan area it is suggested that the Councils look to allocate significantly more sites than may be required to meet the minimum housing need identified in the HEDNA to increase the supply of affordable housing and attempt to address the issue of affordability in both districts (discussed further under Question Q-H2-1 below). This could be reasonably achieved through the application of a reasonable buffer on top of the minimum housing need identified, which the Urban Capacity Study would also appear to recommend.
We have looked at the 5YHLSC as at 31st March to March 2027 and it is our belief that the annual housing provision figure should be between 800 and 850 dwellings per annum. This takes into account the South Warwickshire Plan proposals for a much wider housing supply in form and context for the rural areas where there is very significant population and the need to try to retain growth in settlements and generally the residents staying within their general location. Both Districts have significant requirements for affordable housing and particularly in terms of the housing waiting list for each authority and the annualised figure above of 800 to 850 dwellings per annum allows for significant reductions in housing waiting lists as well as for a substantial increase in the requirement for affordable housing particularly in rural areas. This generally supports the trend-based projections included in Table 9.
As indicated in responses to earlier questions, windfalls must be taken fully into account especially as recent changes in trend will lead to an increasing number of windfalls. If the average number of windfalls over the previous 12 years is used, there is no need to appropriate more land for housing development.
Issue H1: We have looked at the 5YHLSC as at 31st March to March 2027 and it is our belief that the annual housing provision figure should be between 800 and 850 dwellings per annum. This takes into account the South Warwickshire Plan proposals for a much wider housing supply in form and context for the rural areas where there is very significant population and the need to try to retain growth in settlements and generally the residents staying within their general location. Both Districts have significant requirements for affordable housing and particularly in terms of the housing waiting list for each authority and the annualised figure above of 800 to 850 dwellings per annum allows for significant reductions in housing waiting lists as well as for a substantial increase in the requirement for affordable housing particularly in rural areas. This generally supports the trend-based projections included in Table 9. Q-H1.1: We agree with the question as set out in our answer above.
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.
IM Land generally support the proposed trend-based approach using the 2021 census data, which has resulted in an increase of 440 homes per year in comparison with the 2014-based projections. It will be important that the Coventry and Warwickshire Housing Market Area (CWHMA) authorities provide the adequate evidence and justification to support deviating from the current, and potentially future, standard method for calculating local housing need.
2.19 The Government, through the PPG and NPPF, are clear that in most cases, Local Housing Need as derived from the standard method is expected to form the basis of a Local Authorities housing requirement. However, there is clear guidance within the PPG that deviation from the Standard Method is acceptable in exceptional circumstances. In this instance, through the HEDNA, the HMA authorities have set out an argument that the housing requirement for Coventry has been overquantified, and this is demonstrable utilising latest Census data. The HMA propose therefore to utilise a trend-based approach to establish the housing requirement for all authorities. We have no specific comments on this assertion, but would make the following broad comments relating to the eventual 'policy on' housing requirement. 2.20 Whilst the Plan suggests that it is not helpful to meet affordable housing needs by building more market housing, we do not agree with this conclusion and seems to have been included in the Plan to counter arguments that affordable housing need likely necessitates additional housing growth. The HEDNA demonstrates significant affordable housing need within the Plan Area. Whilst the HEDNA correctly warns against trying to directly corelate housing supply with affordable housing need, it is not convincing that the acute need for affordable housing within the Plan area does not require some form of uplift as an integral part of the calculation. Whilst it is clearly not appropriate to deliver a rate of housebuilding to meet the affordable need in full, having regard for the high level of affordable housing need, we do consider some form of uplift remains entirely justified. 2.21 The PPG is also clear that it is necessary to robustly calculate the housing requirement, prior to and independently from any robust assessment of the ability of an area to meet that need. It is further important to ensure the housing requirement reflects the needs of the Plan area, prior to considering the level of unmet needs an area can deliver (we respond to this point in response to Q-H4-2 and Q-H4-3). 2.22 One issue with the proposed approach adopted within HEDNA relates to the 35% uplift applicable to Coventry City as step 4 of the Standard Method. Whilst the approach adopted by the HMA may be correct, and thorough Examination will draw this out, thus it will need to be fully justified. However, we are concerned that this approach negates the reason why the 35% uplift is applicable. 2.23 The 35% uplift was introduced to increase the supply of housing nationally, in the most sustainable locations. This is to get the Country's housebuilding as close to 300,000 annual target as possible. The 35% uplift does not reflect local need (though is applicable to it), and relates to a requirement to deliver uplifts nationally. Thus in terms of national need, some form of uplift remains required, if not in Coventry then within the HMA. Without this, then a significant quantum of supply will be lost, locally, regionally and nationally in direct conflict with the reasoning why the 35% increase was delivered. As such, some form of uplift sensibly remains applicable, though having regard for the issues of Coventry City's capacity, this may need to be dispersed within the HMA. This need remains independent of unmet need, as they solely relate to local need.
It is recognised that the Statistics Regulator and ONS accept that there have been issues with estimating and projecting the population in Coventry and thus it is the Council’s intention to move away from the Standard Method 2014-based household projections and instead use a trend-based projection which takes account of the initial 2021 Census data releases and applies more up-to-date assumptions about fertility, mortality and household formation rates. We do not consider that an alternative approach has been robustly evidenced and exceptional circumstances for this have not been set out. We caution against deviating from the Standard Method as this approach can only be used in exceptional circumstances, and it will be heavily scrutinised at Examination. A lower figure than the Standard Method must have robust evidence to show the figure is based on realistic assumptions of demographic growth and that there are exceptional local circumstances to justify the approach. This has not been demonstrated. This alternative method results in a reduction in the overall housing need for South Warwickshire from 5,554 dwellings per annum to 4,906 dwellings per annum; a reduction of 648 dwellings. Whilst we understand the reasoning behind applying this lower figure, ideally the 2014 projections should continue to be used. If an alternative method is absolutely necessary, a buffer of at least 10% should be added to the identified local housing need in order to ensure choice and competition in the market and to safeguard against any shortfall in the delivery of housing over the plan period. Therefore, the Local Housing Need should be at least 5,396 dwellings per annum. Whatever the housing need, it cannot fully be met on brownfield and greenfield sites so it will be necessary for Green Belt sites such as Clopton Quarter to be released to meet the housing need. This was clearly demonstrated at a previous workshop with ‘Lego houses’ hosted by the South Warks Local Plan team.
26. 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. 27. 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”4. 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. 28. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. 29. 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 Warwi ckshire set out in the HEDNA, HLM have some concerns with the approach taken in the HEDNA to economic growth and affordable housing need. 30. 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. 31. 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 in Warwick 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. 32. The enclosed analysis should be given consideration as the SWLP emerges, to ensure a sufficient level of housing is planned for across South Warwickshire. 33. 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. 34. 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. 35. In line with the NPPF5, 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 guidance6; 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. 36. 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 soundness7, which is explored in further detail in response to Issue H4 below. 37. 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 as set out in the below Table in the order of at least 43,000 dwellings. Table – SWLP Housing Requirement and Supply Calculation Housing Requirement South Warwickshire Minimum Housing Need Derived from the HEDNA (1,679 x 28 Years): 47,012 dwellings Uplift to Minimum Housing Need: TBC – further work required to determine whether an uplift is appropriate Contribution Towards Unmet Needs of Coventry and Birmingham & Black Country: TBC – engagement with Birmingham/Black Country and Coventry required but suggest increase of at least 21,000 dwellings possible (circa 11,000 towards Coventry and at least 10,000 towards Birmingham) Total Housing Requirement: 68,000 dwellings + Housing Supply Sites with Planning Permission at 1st April 2022 (with 5% lapse rate applied): 14,360 dwellings Outstanding Local Plan Allocations at 1st April 2022: 5,579 dwellings Windfall Allowance: TBC – 4,840 dwellings assumed in line with UCS however this requires further justification / compelling evidence Total Housing Supply: 24,779 dwellings Indicative Housing Requirement to be found by the Plan: 43,000 dwellings + 4 Paragraph 61 of the National Planning Policy Framework (July 2021) 5 Paragraph 61 of the National Planning Policy Framework (July 2021) 6 Paragraph 010 Reference ID 2a-010-20201216 of National Guidance 7 Paragraph 35 a) of the National Planning Policy Framework (July 2021)
Issue - H1-1: Support. RBC would agree that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire. Duty to cooperate response: Although the joint HEDNA gives each authority a housing need figure to plan for, government policy is in a state of flux and this figure may change and/or there may be a need for each authority to accommodate growth from Coventry. Given this level of uncertainty we will need to collaborate on planning for housing going forward.
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.
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.
It is acknowledged that there have been issues with estimating and projecting the population in Coventry, meaning population growth in the City has been systematically over-estimated by ONS (dating back to at least 2001) and that the over-estimation works through into population projections that are demonstrably too high and unrealistic. The draft Plan considers that as the overall housing need in Coventry is lower in the HEDNA (compared to the previous 2014-based projections), it follows that the Local Plan will be likely to need to accommodate fewer additional homes from Coventry based on these figures. However, it is important to emphasise that the Planning Practice Guidance is clear in its approach that the ‘standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area’ (Paragraph 010; Reference ID: 2a-010-20190220). The draft South Warwickshire Local Plan should therefore reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing. For example, an appeal decision for up to 800 dwellings at the Former North Warwickshire Golf Club (Appeal Ref. APP/P4605/W/18/3192918 – a decision which was ‘called-in’ by the Secretary of State) highlighted the chronic shortfall in affordable housing which has come forward within Birmingham City since 2011. Paragraph 14.108 of the Inspector’s Report states that only 2,757 new affordable homes were provided in the City over the first 6 years of the Plan period. This represents less than half of the target provision and a net increase in only 151 affordable homes if Right to Buy sales are taken into account. The Inspector goes on to state that given the heavy reliance in the five-year housing land supply on City Centre apartment schemes, it is difficult to see how that trend can be reversed in the short to medium term (paragraph 14.109). Whilst it is noted that Birmingham City Council does not form one of South Warwickshire’s Authorities, it highlights recent difficulties with delivering homes on brownfield sites. The high proportion of flatted developments, coupled with the increased likelihood of viability issues, has led to a chronic shortfall in the provision of affordable homes. Should the South Warwickshire Authorities follow a similar approach, it may therefore be necessary to increase the Housing Requirement, in accordance with national guidance, to improve affordability. We note that work is ongoing to confirm how much housing can be provided from various sources, both in terms of existing and future capacity to help meet the need. This includes an understanding what has already been built, has planning permission or is identified for development in existing Plans and the capacity of small ‘windfall’ sites. Overall, we support a trend-based approach in principle. However, it is considered that any shortfall in housing supply should be regarded as a minimum given that it is currently calculated against an untested housing target that may require an upward adjustment to take account of affordability.
31. It is important to emphasise that the Planning Practice Guidance is clear in its approach that the ‘standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area’ (Paragraph 010; Reference ID: 2a-010-20190220). The draft South Warwickshire Local Plan should therefore reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing. 32. For example, an appeal decision for up to 800 dwellings at the Former North Warwickshire Golf Club (Appeal Ref. APP/P4605/W/18/3192918 – a decision which was ‘called-in’ by the Secretary of State) highlighted the chronic shortfall in affordable housing which has come forward within Birmingham City since 2011. Paragraph 14.108 of the Inspector’s Report states that only 2,757 new affordable homes were provided in the City over the first 6 years of the Plan period. This represents less than half of the target provision and a net increase in only 151 affordable homes if Right to Buy sales are taken into account. The Inspector goes on to state that given the heavy reliance in the five year housing land supply on City Centre apartment schemes, it is difficult to see how that trend can be reversed in the short to medium term (paragraph 14.109). 33. Whilst it is noted that Birmingham City Council does not form one of South Warwickshire’s Authorities, it highlights recent difficulties with delivering homes on brownfield sites. The high proportion of flatted developments, coupled with the increased likelihood of viability issues, has led to a chronic shortfall in the provision of affordable homes. Should the South Warwickshire Authorities follow a similar approach, it may therefore be necessary to increase the Housing Requirement, in accordance with national guidance, to improve affordability. 34. We note that work is ongoing to confirm how much housing can be provided from various sources, both in terms of existing and future capacity to help meet the need. This includes an understanding what has already been built, has planning permission or is identified for development in existing Plans and the capacity of small ‘windfall’ sites. 35. Overall, we support a trend-based approach in principle. However, it is considered that any shortfall in housing supply should be regarded as a minimum given that it is currently calculated against an untested housing target that may require an upward adjustment to take account of affordability.
As explained within both the consultation material and Planning Practice Guidance (“PPG”) population projections form the basis of the standard method for calculating housing need (Paragraph: 005 Reference ID: 2a-005-20190220). However, the 2022 HEDNA demonstrates the inaccuracy and over projection of ONS population estimates in comparison to the 2021 Census data across the HMA, this is set out within table 1 below. Table 1: Percentage difference between ONS MYE (2020) and 2021 Census population difference Housing Market Area --------- ONS MYE (2020) -- 2021 Census -- Percentage Difference Coventry ------------------------- 379,387 --------------- 345,300 -------- -9% North Warwickshire ----------- 65,452 ---------------- 65,000 --------- -1% Nuneaton and Bedworth ---- 130,373 -------------- 134,200 -------- 3% Rugby ---------------------------- 110,650 --------------- 114,400 -------- 3% Stratford-on-Avon ------------- 132,402 --------------- 134,700 -------- 2% Warwick ------------------------- 144,909 --------------- 148,500 -------- 2% Coventry & Warwickshire --- 963,173 --------------- 942,100 -------- -2% Similarly, paragraph 5.44 of the 2022 HEDNA at page 90 states: “On the 29th July, ONS published its response setting out a work plan to address the OSR recommendations.19 ONS recognised that there were concerns about population estimates and projections (specifically mentioning Coventry) and that this can have an impact on household projections and therefore calculations of housing need. It is notable that both ONS and the OSR have acknowledged issues with the population estimates for Coventry and its impact on the City’s calculated housing need.” When considering the evidence put forward by the 2022 HEDNA it is evident that circumstances warrant an alternative approach to the standard method as set out by paragraph 61 of the NPPF (2021) in order to better reflect the household populations projections and subsequent needs of both Coventry, South Warwickshire and the HMA more widely: “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. In addition to the local housing need 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.” The divergence from the standard method and the use of remodelled projections by the 2022 HEDNA does amount to a significantly lower projected housing needs in comparison to the traditional standard method for Coventry. However, when viewed in the context of Stratford-on-Avon and Warwick a higher housing need figure is calculated, the SW councils should seek to meet this need in full. The WMHAPC welcomes the SW councils’ acknowledgement of their Duty-to-Cooperate in planning for the anticipated unmet housing needs of Coventry within Warwickshire and Stratford-on-Avon. However, it is important to note that it is plausible that through a review of their own Development Plan Coventry City Council could take a different approach to calculating overall housing need which may result in a higher quantum of unmet need for Coventry which would need to be accommodated within South Warwickshire.
Strategic cross boundary issue 1 Development Requirements - The Issues and Options (I&O) document refers to the Coventry & Warwickshire Housing and Economic Development Needs Assessment (HEDNA). NBBC have commissioned a report called 'Towards a Housing Requirement for Nuneaton & Bedworth', which is intended to supplement and be read alongside the HEDNA. The report considers wider issues than those covered in the HEDNA which will impact on Nuneaton and Bedworth Borough's development requirements and may have implications for the South Warwickshire Plan. The report provides justification that NBBC should plan for higher housing provision than the minimum housing need of 409-437 dpa identified in the HEDNA and is referenced in Table 9 of the I&O document. The report recommends provision of a housing target of around 545 dpa as necessary to positively support economic growth, sustainable regeneration of town centres, and the delivery of affordable housing. Strategic cross boundary issue 2 Duty to Cooperate - the statutory duty to cooperate to achieve sound plans required each Council sign Memorandums of Understanding committing to delivering the unmet housing and employment needs of Coventry City Council. The current consultation on the revised NPPF indicates the duty to co-operate is to be replaced with an alignment policy. The details of the alignment policy are not yet known and will be subject to a further consultation. The duty will remain in place until the alignment policy comes into effect. NBBC has withdrawn from the current memorandum of understanding (MoU) and will seek to negotiate an appropriate arrangement with sub-regional partners which will support the required growth in the Borough. Strategic cross boundary issue 3 Work on other strategic matters have been instigated across the wider sub- region through the Coventry, Solihull and Warwickshire Association of Planning Officers (CSWAPO). The outcomes of this research should enable informed choices as work on respective Plan reviews progress.
2.32 It is acknowledged that there have been issues with estimating and projecting the population in Coventry, meaning population growth in the City has been systematically over-estimated by ONS (dating back to at least 2001) and that the over-estimation works through into population projections that are demonstrably too high and unrealistic. 2.33 The draft Plan considers that as the overall housing need in Coventry is lower in the HEDNA (compared to the previous 2014-based projections), it follows that the Local Plan will be likely to need to accommodate fewer additional homes from Coventry based on these figures. 2.34 However, it is important to emphasise that the Planning Practice Guidance is clear in its approach that the ‘standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area’ (Paragraph 010; Reference ID: 2a-010- 20190220). The draft South Warwickshire Local Plan should therefore reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing. 2.35 For example, an appeal decision for up to 800 dwellings at the Former North Warwickshire Golf Club (Appeal Ref. APP/P4605/W/18/3192918 – a decision which was ‘called-in’ by the Secretary of State) highlighted the chronic shortfall in affordable housing which has come forward within Birmingham City since 2011. Paragraph 14.108 of the Inspector’s Report states that only 2,757 new affordable homes were provided in the City over the first 6 years of the Plan period. This represents less than half of the target provision and a net increase in only 151 affordable homes if Right to Buy sales are taken into account. The Inspector goes on to state that given the heavy reliance in the five-year housing land supply on City Centre apartment schemes, it is difficult to see how that trend can be reversed in the short to medium term (paragraph 14.109). 2.36 Whilst it is noted that Birmingham City Council does not form one of South Warwickshire’s Authorities, it highlights recent difficulties with delivering homes on brownfield sites. The high proportion of flatted developments, coupled with the increased likelihood of viability issues, has led to a chronic shortfall in the provision of affordable homes. Should the South Warwickshire Authorities follow a similar approach, it may therefore be necessary to increase the Housing Requirement, in accordance with national guidance, to improve affordability. 2.37 We note that work is ongoing to confirm how much housing can be provided from various sources, both in terms of existing and future capacity to help meet the need. This includes an understanding of what has already been built, has planning permission or is identified for development in existing Plans and the capacity of small ‘windfall’ sites. 2.38 Overall, Ellis Machinery support a trend-based approach in principle. However, it is considered that any shortfall in housing supply should be regarded as a minimum given that it is currently calculated against an untested housing target that may require an upward adjustment to take account of affordability.
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.
The housing supply figure, based on the wider Warwickshire SHMA evidence, against the current Standard Method of 1,679 dwellings for the local plan area is noted. Clearly the SWLP is at an early stage of preparation and the NPPF update and amendments to the Levelling Up Bill (referred to above) are likely to have implications to this plan making process, testing of the local plan and any ‘locally derived’ housing supply figure. On this basis it is queried as to whether any consideration has been given to revising the housing supply, development strategy and timetable etc. by the two South Warwickshire councils.
As per our Liberal Democrat group submission, I believe that the figure of 868 homes a year is excessive. The existing methodology needs to be reviewed.
Yes The HEDNA is a standard and tried and tested model so Claverdon accepts the general approach in the plan subject to infrastructure as set out earlier.
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 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 868dpa are required in Stratford-on-Avon and 811dpa in Warwick District. Therefore moving towards a trends based approach would seem appropriate. In terms of the approach for the HEDNA, it is noted that Table 8.13 – Estimated Need for Social/Affordable Rented Housing by Local Authority, identifies a net annual need for 419 affordable dwellings in Stratford-on-Avon and 582 affordable dwellings in Warwick District. This equates to 67% and 52% of the identified overall housing requirement respectively for the two authorities. 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. 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. However, it is not realistic to generally expect housing allocations to deliver 67% or 52% affordable housing. There is, therefore, the possibility that there will be a shortfall of affordable housing provision during the course of the plan period. One way to overcome this would be to increase the total housing figures included in the SWLP Consideration should, therefore, be given to uplift the housing requirement to ensure that an appropriate amount of affordable housing can be provided.
No answer given
The HEDNA is a standard and tried and tested model so the JPC accepts the general approach in the plan. Two points are worth highlighting 1. Since 2014 the total and balance of housing need has changed significantly between Stratford and Warwick Districts and both Councils have exceeded their housing targets in the period. This indicates some caution in future projections and a significant need for flexibility in local targets. 2. There are no major proposals for economic development or transport links centred on Henley/Beaudesert which casts doubt on the ability of the plan to deliver sustainable growth.