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
RPS recommends that the adjustment for household suppression presented in the HEDNA is reasonable and consistent with national policy and guidance and so should be taken into account in determining the scale of housing need in the SW area.
Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of “significantly boosting” the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. 4.2. The Planning Practice Guidance (PPG) (para 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. 4.3. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Hosing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the Joint Plan area. 4.4. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle. The trend based figures, which equate to an overall housing need across the Joint Plan area of 1,679 dwellings per annum is supported in principle. 4.5. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. 4.6. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now, and will continue to exist in the future. 4.7. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix E) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear." 4.8. It is important to stress that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted Birmingham Development Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed into the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further. NPPF REF
No answer given
Issue Q-H1-1. Following on from the importance of the link between housing and the local economy, the Chamber supports the use of the “trend –based “ approach/methodology in establishing the appropriate level of housing requirements .The alternative (2014- based household projection method)set out would seem to “bake in “ a shortfall of housing relative to recent market performance. This could lead to undesirable consequences for the local economy.
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 identifying future levels of housing need across South Warwickshire? A trend based model should be used to future housing need, but NOT SNPP or the HEDNA – The census proved the SNPP spectacularly wrong. The HEDNA, however, fails to get right births, deaths, windfalls and student movements. It needs to be more detailed, fully transparent, and based on historic trends, not models and fudge factors [UPC]. Taking into account the 5 Dec 2022 letter from Michael Gove, Secretary of STate to MPs, The housing needs assessment should not include the 35% uplift for the 20 largest towns [locally Birmingham and Coventry], any unmet needs for neighbouring authorities, nor any affordability factor which is discredited. It has not been shown to reduce house prices. The true housing need of the area is grossly overestimated. Q-H1-2 –If your answer to H1-1 is No, what would be a more appropriate approach to calculating future housing needs for this Local Plan The modelling needs to be fully transparent – we need full access to the spreadsheets and assumptions used in the ICENI model which has been denied thus far. Any new model needs to include a full range of administrative data, [school admissions, electoral role, student migration, pensions, benefits, gas & electric use, waste tonnage, student destinations after graduation, home office visa data, house sales, house completions, house sales, job creation etc] especially relating to student migration and internal migration [HESA destinations data, Home Office visa data, especially the exit checks data]. Windfalls need to be estimated accurately. If windfalls continue as in the recent past, [ca 900/yr] the HMA will exceed the housing need identified in the HEDNA. Future trends should be firmly rooted in the actual recent past, projecting forward recent trends, not in any way relating to ONS discredited methods.
A trend based model should be used to future housing need, but NOT SNPP or the HEDNA – The census proved the SNPP spectacularly wrong. The HEDNA, however, fails to get right births, deaths, windfalls and student movements. It needs to be more detailed, fully transparent, and based on historic trends, not models The modelling needs to be fully transparent – we need full access to the spreadsheets and assumptions used in the ICENI model which has been denied thus far. Any new model needs to include a full range of administrative data, [school admissions, electoral role, student migration, pensions, benefits, gas & electric use, waste tonnage, student destinations after graduation, home office visa data, house sales, house completions etc] especially relating to student migration and internal migration. Windfalls need to be estimated accurately. If windfalls continue as in the recent past, [ca 900/yr] the HMA will exceed the housing need identified in the HEDNA
No: The HEDNA is NOT a reasonable basis for assessing future need because: 1. It assumes a very low level of windfalls, just 220/yr, when the actual figures have averaged 901/year. 1. If the actual average since 2011 – 901 - is used, the plan is in surplus: 5,255 excess house spaces in 2040; 3610 excess in 2045. 1965 in 2050. 2. The HEDNA wrongly assumes that the ONS treatment of births and deaths in the Mid Year Estimates is broadly correct, after adjusting fertiility rates. The graph below, shows a sharp divergence between what ONS predicted in SNPP2014 [which is calculated in the same way as the MYE], and reality, especially in Coventry. 1. Across the region, and especially in Coventry, ONS has grossly overestimated births, and underestimated deaths. In 2021 The overestimate of births in the HMA was 1700 [comparing actual vs SNPP2014] . Converseley, in 2019, the last ‘normal’ year before the pandemic, deaths across the HMA were underestimated by 633. Taking births and deaths together, natural change was overestimated by [1700+633] = 2333 in a single year. If this gap between forecast and reality continued across the plan, housing need would be overestimated by 27,387. 2. ONS forecasts of births and deaths [in the SNPP and MYE] are NOT a reliable basis for projecting future population change and consequent housing need. We disagree with the underlined statement in the HEDNA, “5.122 When looking at migration our starting point is to consider how different migration has been over the 2011-21 period than was previously estimated by ONS. Essentially the difference in population growth between the two sources is likely to be attributable to migration, this is on the basis that it is expected that births and deaths have been fairly well recorded by ONS. While we trust the recording of births and deaths, we do not accept at all the ONS forward forecast of births and deaths – adjusting fertility and mortality rates upward will make these forecasts worse, not better if ONS trend assumptions, of increasing births, and decreasing deaths, are followed. . Q-H1-2: If your answer to H1-1 is No, what would be a more appropriate approach to calculating future housing needs for this Local Plan? WE NEED TO SEE THE FULL MODELLING. It is impossible to critically evaluate the HEDNA because the underlying spreadsheets have been concealed. EIR requests to all of the HMA local authorities for the modelling beneath the HEDNA were refused on the grounds that the information is confidential. This is an absurd claim. Without being able to see the working, and the assumptions, the public cannot exercise it’s right, under the Aarhus convention to participate in Environmental decision making. We are being told by Iceni “Trust us. These are our conclusions.” This totally prevents proper scrutiny. In contrast, ONS, despite their other failings, does make available the full components based spreadsheets for future growth, including births, deaths, internal immigration and emigration, international immigration and emigration, and cross border migration. The best guide to future housing need, at present, is to forecast forward the actual population growth of the last 10 years and housing completions. This is the best data we have, as rough and ready as it may be. Current data, about migration, is extremely poor, both for international migration and internal migration. At the very least, any model should include 1) knowledge of the movement of foreign students, which can be obtained from HESA data and the Home office exit checks data. Student movement needs close attention. For Coventry, in 2014-15, the SNPP hugely understated emigration among foreign students, at the two Coventry universities by 3,500-4,000/yr. Population modelling must include the latest administrative data including the electoral role, car ownership, gas and electric usage, refuse collected, housing completions, pensions and benefits, numbers of student accommodations, school populations, jobs created, economic growth, NI registrations, new GP registrations, vaccinations etc. The HEDNA has not incorporated most of these figures. The SNPP rely on unreliable sources: the International Passenger Survey for international migration, and GP registrations for internal migration. There is better information available.
1. Yes, a trend based approach should be adopted in place of the 2014 projections, which were completely discredited by the Census. But these should be real historic trends, not modelled trends, and should have no link to ONS projections. 2. No. The HEDNA is NOT a reasonable basis for identifying future housing needs in the area, for the reasons stated above and below. [see Q-H1-1 above] 1. Births and Deaths are not adequately and correctly death with – Given that ICENI has adjusted fertility rates upward, this will worsen the mistakes made in the SNPP relating to natural change. Actual births have been far below what ONS have predicted. [see above Q-H1-1] Extrapolating births from the last 10 years, will give the best result with births. Similarly for deaths. 2. Migration, which is a major source of error, in the ONS forecasts,[ie the SNPP] , has not been sufficiently analysed. In particular, student movements need to be identified from HESA data, HESA graduate destimations surveys, the census, and exit checks data. In 2014/15, the SNPP underestimated the number of students leaving the area, mainly to go overseas, by at least 3,500-4000 in a single year. In 2018/19, the SNPP underestimated the numbers of students leaving Coventry – by 5,500-6000. [this analysis is derived from the Exit Checks Data which found that 96% of international non EU students leave t he country promptly after graduation, and of those that return, 85% leave Coventry after graduation [from the Destinations Survey] To come to an accurate model, a new assessment needs explicitly to model student movements, from available data. 3. We also clearly need to understand how much student accommodation has been included in completions over the last 10 years – varying formulae have been used [sometimes 1 dwelling for each unit with a kitchen which could house 4-8 persons; sometimes 1 dwelling for each 2.5 student residents] - , because future growth will not need to repeat this provision. The needs for family type accommodation will be less than suggested by the gross completions over the last 10 years. It is our estimate, that in the last 10 years in Coventry, roughly 5000 dwellings have been student units in purpose built accommodation. Actual need for family homes, will be less than the gross figures for the last 10 years. 4. The HEDNA assumes requirements which no longer apply, since the letter of 5 Dec 2022 from the Secretary of State to MPs. The letter removed the duty to cooperate, removed the requirement of the standard method, removed the uplift for 20 large cities [locally Birmingham and Coventry] removed the 5 year land supply requirement. The local plan should explicitly enshrine these freedoms in the new local plan and state that housing needs from outside Warwickshire will only be accepted on a voluntary basis by the local authorities, on a case by case consideration. The Local Plan [and the HEDNA] should state that there is no duty to accept unmet housing need from Coventry, Birmingham, or any other local authority.
Hill Residential 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 CWHMA authorities provide the adequate evidence and justification to support deviating from the current, and potentially future, standard method for calculating local housing need.
The HEDNA proposes that we move away from an approach where future needs are based on 2014 household projections towards a trend-based approach. The council’s view is that there is no way anyone can say whether this is reasonable or not, since all methods are based on educated guesswork. The concept of being able to accurately predict the need in 2050 is doubtful. 5-year reviews of what is actually happening in the plan area will be critical. The fact that the projections place an even higher development burden on South Warwickshire than the 2014 figures is a cause for concern. We are not sure that the numbers involved, in terms of both employment land and housing, are actually sustainable. The burden could prove to be too high both for the countryside, the environment and our infrastructure. In addition, to cope with the projected growth there is bound to be an impact on the Green Belt. Whilst we think that Greenbelt allocation needs challenging and changing, if guidelines on building on Greenbelt land stay the same, or get stricter, a lot of options are blocked. If this were the case, we very much doubt the ability of the remaining countryside to deal with the projected growth in a sustainable way.
Local Housing Need 4.69 As part of the emerging evidence, the IO document refers to an updated Housing and Economic Development Needs Assessment (HEDNA) that has been produced for the whole of Coventry and Warwickshire Housing Market Area (C&WHMA) using the latest information from the 2021 Census. As rightly stated, the HEDNA uses as the starting point for assessing housing need the standard method set out in Planning Practice Guidance (PPG). 4.70 The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire. Nonetheless, the HEDNA has modelled an alternative approach based on the Census 2021 early data releases from June 2022, based on apparent issues with estimating and projecting the population in Coventry, particularly relating to potential discrepancies in the estimates of the population that have informed the 2014-based household projections. The alternative need figure is 4,906 dwellings annually across the sub-region. 4.71 Table 9 of the IO document (and Table 15.1 of the HEDNA) shows a breakdown of the overall housing need for each constituent local authority. 4.72 RPS notes that under the alternative ‘trend-based’ (‘revised standard method’) projection the need is higher for both SW authorities compared to the standard method need figures (1,679 dpa under the alternative projection, versus 1,239 dpa using the standard method), an extra 440 homes per annum across the SW area. The trend-based projection is also higher in Rugby, but lower in North Warwickshire and Nuneaton & Bedworth, and substantially lower in Coventry. 4.73 The HEDNA goes to great lengths to explain why an alternative approach to the standard method for estimating local housing need across the sub-region is justified on the basis of ‘exceptional circumstances’, which is required to meet the policy test set out at paragraph 61 of the NPPF. In a nutshell, when looking at population change over the preceding period (2011-2021) the HEDNA claims that a discrepancy exists between the population (mid-year) estimates devised by ONS, and those derived from the Census 2021 population count. 4.74 Table 5.2 and 5.3 of the HEDNA seeks to illustrate this discrepancy. These tables show that population across the sub-region was substantially lower in the Census (942,100) compared to the mid-year estimates (963,173), largely as a result of an over-estimate in the population for Coventry. However, it is also notable that the Census output shows a higher population for both Stratford-upon- Avon and Warwick districts, a total difference of 6,316 extra people residing in South Warwickshire in 2021. This additional number of people will clearly have an impact on future population estimates for the SW area when properly accounted for in future projections. 4.75 On this basis, paragraph 5.105 explains the HEDNA proposes a trend-based projection taking account of the 2021 Census, more recent data around fertility and mortality, analysis of recent migration trends, from which household estimates are then derived (using the 2014-based household formation rates). The remodelled household projections are then fed back into the standard method through the application of the affordability adjustment, to generate the overall housing need figures for each area. 4.76 The local housing need derived from the trend-based projections is provided at Table 5.33 of the HEDNA. Whilst the overall approach is broadly understood, reference is made at paragraphs 5.149-5.150 of the HEDNA to a ‘further adjustment to deal with any suppression of household formation within the projections’ and ‘part return to trend’ analysis based on a refinement of the 2014-based household representative rates (HRRs). The results from the adjusted HRRs are shown in Table 5.34. The figures show an increase in household growth across the sub-region (by +3,000) compared to baseline trend-based projection, and increased household growth for Stratford-upon- Avon and Warwick districts. However, the HEDNA does not consider any further what implications this adjustment might have for the estimate of overall housing need across the sub-region, or for the SW area specifically. 4.77 RPS recommends that the adjustment for household suppression presented in the HEDNA is reasonable and consistent with national policy and guidance and so should be taken into account in determining the scale of housing need in the SW area.
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.
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.
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.
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.
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.
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.
Q-H1-1: Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Bellway 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, Bellway 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, Bellway 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 SWLP 43,000 dwellings +
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 identifying future levels of housing need across South Warwickshire? The latest HEDNA suggests exceptional circumstances exist to move away from the Standard Method for determining housing need as there are alleged issues with existing census data in estimating and projecting the population in Coventry. The HEDNA has therefore modelled new demographic projections which take account of the initial 2021 Census data releases and seeks to assess how the population can be expected to change over time by applying more up-to-date assumptions about fertility, mortality and household formation rates. The HEDNA then applies these alternative projections through the framework provided by the standard method. The HENDA suggests that, based upon the trend-based projections, whilst the housing need in Coventry City may have reduced, the housing need for Stratford-on-Avon has increased from 564 to 868 dwellings per year (304 dwellings per year / 53.9% increase). Similarly, the need for Warwick District has increased from 675 to 811 dwellings per year (136 dwelling per year / 20.1% increase). The total housing need for both Districts (and therefore South Warwickshire) has accordingly increased from 1,239 to 1.679 dwellings per year (440 dwellings pear year / 35.5% increase). The housing need across the Plan Period has therefore increased from 30,975 to 41,975. This figure represents the minimum need that should be planned for and does not include any unmet need from neighbouring authorities (such as Coventry or Birmingham) which may be accommodated, or any addition homes that may be planned for to meet other socio-economic objectives (such as increasing affordable housing provision – see answer to Question H2-2). Should the Authorities choose to pursue the trend-based alternative, they must accept that their housing need increases substantially and that this need must be met, as a minimum. It would not be acceptable to reduce the level of housing provided within Coventry based on a new trend based model, whilst seeking to retain the need for Stratford and Warwick suggested by the older Standard Method – model consistency is required.
The latest HEDNA suggests exceptional circumstances exist to move away from the Standard Method for determining housing need as there are alleged issues with existing census data in estimating and projecting the population in Coventry. The HEDNA has therefore modelled new demographic projections which take account of the initial 2021 Census data releases and seeks to assess how the population can be expected to change over time by applying more up -to-date assumptions about fertility, mortality and household formation rates. The HEDNA then applies these alternative projections through the framework provided by the standard method. The HENDA nonetheless suggests that, based upon the trend-based projections, whilst the housing need in Coventry City may have reduced, the housing need for Stratford-on-Avon has increased from 564 to 868 dwellings per year (304 dwellings per year / 53.9% increase). Similarly, the need for Warwick District has increased from 675 to 811 dwellings per year (136 dwelling per year / 20.1% increase). The total housing need for both Districts (and therefore South Warwickshire) has accordingly increased from 1,239 to 1.679 dwellings per year (440 dwellings pear year / 35.5% increase). The housing need across the Plan Period has therefore increased from 30 ,975 to 41,975. This figure represents the minimum need that should be planned for and does not include any unmet need from neighbouring authorities (such as Coventry or Birmingham) which may be accommodated, or any addition homes that may be planned for to meet other socio-economic objectives (such as increasing affordable housing provision – see answer to Question H2-2). Should the authorities choose to pursue the trend-based alternative, they must accept that their housing need increases substantially and that this need must be met, as a minimum. It would not be acceptable to reduce the level of housing provided within Coventry based on a new trend based model whilst seeking to retain the need for Stratford and Warwick suggested by the older Standard Method – model consistency is required.
Q-H1-1: Yes, but subject to review, in light of expected changes to the planning system.
H1- Numbers Figure 22 – ends in 2009. The table should be replaced with one which shows the latest figures – government statistics are available up to 2021.The rationale for calculating figures seems to be sound.
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.
Q.1.1 Moving away from the 2014 figures is clearly sensible. The world has changed a lot since then, but the new figure of 35,000 is far too high. Every forecast ever made is usually proved to be incorrect in some respects . A better way is to seek evidence from local Parish/ Town council representatives about housing need in their area. Many of the house built recently have been bought by people moving into the area, not meeting local need. More small one/two bedroom bungalows are needed for elderly local people wishing to downsize and remain within their locality to benefit from the support network they are already familiar with.
Q-H1-1: HEDNA and housing requirement 10. The provision of a sufficient level of housing growth in the SWLP is required in national planning policy, specifically NPPF11(a) and (b). The SWLP Issues and Options is informed by the Coventry and Warwickshire Housing and Economic Development Needs Assessment (‘the HEDNA’, November 2022). This identifies a need for 868dpa for Stratford District and 811dpa for Warwick District, equating to 1,679dpa for the SWLP area. Over the 28-year plan period to 2050 this is a requirement for 47,012 dwellings. 11. Nevertheless, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national policy and guidance (NPPF61 and NPPG0102). 12. Further consideration will also need to be given to unmet needs of neighbouring authorities in line with the Duty to Cooperate and the positively prepared test of soundness (NPPF35a). We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Coventry and Warwickshire; and Greater Birmingham and Black Country.
Chapter 6 Delivering Homes that meet the needs of all our Communities Issue H1: The right number of homes 30. Although the consultation identifies the need to increase the delivery of affordable homes as a key issue for the Plan, as para 11 of the NPPF states plans should promote a sustainable pattern of development that seeks to meet the development needs of their area and as a minimum provide for objectively assessed needs for housing. There is a therefore a need for the Plan to meet the needs of everyone in South Warwickshire. This will include a need to deliver new open market housing, not just affordable housing. 31. The Issues and Options consultation explains that if the Councils use the standard methodology based on 2014 household projections this results in a need for 5554 new houses per annum across the HMA. • 564 per annum in Stratford-on-Avon and • 675 per annum in Warwick In contrast, using a trend-based projection reduces the HMA total to 4,906 per annum but increases the need within south Warwickshire to • 869 per annum in Stratford-on-Avon and • 811 per annum in Warwick 32. As set out in the NPPF (para61) the determination of the minimum number of homes needed should be informed by a LHN assessment using the Government’s standard methodology unless exceptional circumstances justify an alternative approach (para 61). The Authorities would therefore need to justify what exceptional circumstances were in play that warranted departing from the standard method. 33. The HBF would support the higher numbers of housing for Stratford-on-Avon and Warwick of the trend-based approach but suggest the Authorities may wish to further consider the justification for the higher number required. Any departure from standard method of calculating need can be only be supported in exceptional circumstances. However, using the standard method as intended, as a minimum (not maximum) figure, enables the Authorities to arrive at a higher housing requirement. The standard method and the trend-based approach do not need to be seen as being two different (and competing) methods. An approach using the Standard ethod plus an adjustment for trend-base information is possible. 34. The Standard Method plus additional housing for trend-based reasons could then be further supplemented with additional housing required to meet the unmet needs of neighbouring authorities (see comments later on) and/or increased further to reflect the economic ambitions for growth of the area. 35. The HBF agrees that South Warwickshire Plan should include housing to meet the unmet needs of the Birmingham and Black Country, and the Coventry areas (see comments on Issues H4). 36. The South Warwickshire Plan’s policies should ensure the availability of a sufficient supply of deliverable and developable land to deliver the housing requirement. This sufficiency of Housing Land Supply (HLS) should meet the housing requirement, ensure the maintenance of a 5 Year Housing Land Supply (5YHLS) and achieve Housing Delivery Test (HDT) performance measurements. 37. The HBF notes that work is ongoing to confirm how much housing can be provided from various sources, in terms of both existing and future capacity, to help meet the housing needs. The HBF and its members would welcome the opportunity to comment on this work as it emerges. It will be important to review sites with planning permission and those identified for development in existing Plans to ensure they remain deliverable and viable. The HBF comments on windfall can be found in the Urban Capacity Study section of this response. 38. The Government’s objective of significantly boosting the supply of homes set out in the NPPF (para 60) is important. The soundness of strategic and non-strategic site allocations will be tested in due course at the Local Plan Examination. The HBF would not wish to comment on individual sites proposed for allocation, but it is noted that the Council will need to provide a site by site analysis to check of the deliverability of individual site allocations. 39. HBF responses are submitted without prejudice to any comments made by other parties, but it is critical that the Councils’ assumptions on lapse rates, non-implementation allowances, lead in times and delivery rates contained within its overall HLS, 5YHLS and housing trajectory are correct and realistic. These assumptions should be supported by parties responsible for delivery of housing and sense checked by the Councils. The housing trajectory will be an important part of the evidence base and should provide as much detail as possible.
Q-H1-1 and H1-2 36. Whilst Braemar have reservations about the soundness of the methodological approach adopted in the Coventry and Warwickshire Housing and Economic Needs Assessment (HEDNA), we are supportive in principle of the higher levels of growth identified for Warwick and Stratford-on-Avon areas.
H.1.1 No; Future levels of housing need, as evidenced in the HEDNA, are seriously overestimated. Firstly, you apply an affordability uplift (a theory discredited since 2004, yet you are still using it). This theorises that if you build enough houses, prices will fall. This increases number proposed by 42% beyond agreed actual need. This is a massive imposition on rural South Warwickshire Secondly, under the Government allocations for 20 major cities, Birmingham has a 35% automatic uplift applied. This would give Birmingham three times its actual housing need. Under the Duty to co-operate you are considering accommodating this 35% of additional housing. So you will be building housing we don’t want for a Birmingham need that doesn’t exist! H1.2 See the points made above: 1. Since 2011 average brownfield sites available have been enough for 901 dwellings per annum. The SWLP assumes less than 25% of this will materialise (220 DPA). Furthermore, only windfalls for fewer than nine houses are included. This means that land adjacent to Leamington Spa station, home to multiple blocks of flats, the two airfields south of Stratford, with mega housing developments, or the land vacated by King’s High moving out of the town centre, would not ‘count’. 2. If you take the average windfalls every year since 2011, more than the numbers assessed to 2050 can be accommodated. (Excess of 1,965 by 2050). 3. Even taking an ultra-conservative approach of only 50% of the average sites since 2011 becoming available, there is still only a need for 9310 non-windfall housing sites by 2050. 4. On top of this, the ‘affordability uplift’ discredited since 2004, but still applied in the SWLP, adds 42% to the actual agreed housing numbers. 5. These numbers do not reflect actual local need. Houses built across South Warwickshire in response to Coventry’s extraordinary projection of 32% growth (when ONS numbers clearly show 17,000 fewer households than Coventry predicted) have led to massive in-migrations from elsewhere. ONS estimates 76% of Warwick’s population growth since 2018 has been down to this artificially induced in-migration. And 118% of Stratford’s. (ie on actual growth, Stratford’s population would decline.) 6. Lastly, this plan goes out to 2050. Most plans only extend 15 years. 15 years is ample time for forward planning and getting the correct infrastructure in place. Extending from 2040 to 2050 increases SWLP housing numbers by 50%. This is a massive imposition on a rural area. Please reconsider all the erroneous assumptions outlined above in your forward planning for the SWLP. And come up with more realistic housing needs numbers.
Yes, but subject to review, in light of expected changes to the planning system.