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
Housing Needs Assessment Kenilworth and Warwick District more broadly were asked to commit to a large amount of house building within the last local plan. Given the evidence of the census of 2021 it appears that the basis of these calculations was seriously flawed, especially the requirement to provide for Coventrys housing needs. We therefore find ourselves in a self-fulfilling prophecy; we are building more homes, therefore the population of our district is growing, therefore the calculation assumes we need more new homes. This logic is extremely flawed and the calculation of the future housing needs of the district must recognise this and return us to something that is more reasonable and realistic in terms of the future numbers for the district.
4.1. 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) (paragraph 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 2) 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.
Issue H1: Providing the right number of new homes Notwithstanding the comments above regarding the important retail role the Maybird Shopping Park currently plays, there could be an opportunity in the future for mixed-use, residential led development on part or across all of the retail park, which would increase the density of development in this sustainable location. As noted above, Hermes has responded to the Call for Sites, to propose the Maybird Shopping Park as a potential housing development site. Once the Council has reviewed the further sites submitted as part of the Call for Sites exercise in terms of their availability, suitability and deliverability, there should be a better understanding of future capacity.
4.1. 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) (paragraph 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 2) 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.
Although the HEDNA provides a good basis for older people housing with care projections of future demand, we feel it is limited in its reliance on POPPI projections. We don’t believe any interaction with the county council took place to input into the HEDNA in terms of need for working age adults and specialised accommodation. To identify the future need of those with physical disabilities, learning disabilities, autism and sensory issues we suggest that this also considers WCC information on demand or need from the operational social work teams. For this local plan it would be positive to see partnership work between the district/borough housing authorities and the county council for future planning and projecting need for housing with care across the south. The county council do have opportunity to provide data and oversight of the demand being seen from operational social work teams regarding gaps in provision and where the demand sits across the south of the county. It is important to ensure that housing need and commissioning messages about housing with care are being aligned in local housing plans and county council commissioning strategies. WCC would also welcome a revised approach to the S.106 local connection criteria. This heavily prioritises a local connection, and while WCC recognises the importance of this for many of the people it supports, it is contrary to the wider reciprocal arrangement approach to housing across England to support those experiencing Domestic Abuse. WCC would welcome further engagement on this criterion to find a solution which both protects local housing for local needs, but also recognises the absolute need for reciprocal housing arrangements for those experiencing Domestic Abuse.
You should take more note of 'Windfalls' looking at their average over the past decade or so - this indicates there is no need to appropriate more land for housing. WINDFALLS • The SWLP allows for land for 220 dwellings per annum (DPA) from windfalls. • Actual annual average windfall numbers since 2011 have been 901. • 69% of Stratford’s housing site needs since 2011 have been met from Windfalls; 44% of Warwick’s. • If instead of 220 DPA’s (as in plan) the SWLP assumed only half the annual average, (450 homes) the housing land shortfall drops from 23,000 to 1510 in 2040; 5,410 in 2045 and 9310 in 2050. • 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. • In addition to a severe underestimate of overall numbers, the Local Planning guidance only includes within the 220, those spaces for fewer than 9 dwellings. So places like the Ford Foundry site, the King’s High School sites, land adjacent to Leamington Spa Station, and others for more than 9 homes would not be included. • We believe that this also seriously distorts likely available land, based on figures since 2011. 2. AFFORDABILITY UPLIFTS • Under a formula devised in 2004, housing numbers are automatically increased in more expensive areas, on the assertion that building more houses will bring down prices. • This has nothing whatsoever to do with actual housing need. • ONS numbers from the base year used (2014) assessed the SWLP area need at 874 homes. The Affordability formula increases this to 1,239. These are the numbers used in the SWLP. • This is an increase of 42% over need. 2. IN-MIGRATION • Housing numbers like Coventry’s encourage net in-migration to local areas. They are not a response to endogenous growth. • 76% of Warwick’s estimated population growth for 2018-2028 comes from net in-migration. • 118% of Stratford’s is from the same source. (ie. Just on birth rate, without in-migration, the population would decline). • This therefore risks becoming a self-replicating cycle. (“We’ve filled more houses, therefore we need more houses, therefore…”)
4.1. 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) (paragraph 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 2) 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.
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. 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.
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 anet 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.
According to the latest census the population of Coventry, Warwick and Kenilworth has not grown as predicted. As such future development of new housing of the numbers being proposed is questionable. Maybe new homes should be estimated on a more robust and proven model of evidence based rather than built on a contentious prediction. It is obvious that different areas of Warwickshire will have different population expansions. A blanket approach is insufficient.
RPS welcomes the preference for the alternative ‘trend-based’ projection set out in the HEDNA, which underpins the local housing need figures set out in the IO document. Nonetheless, RPS recommends that the adjustment for household suppression presented in REPORT | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 18 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.
4.1. 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) (paragraph 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 Housing 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 2) 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.
4.1. 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) (paragraph 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 Housing 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 2) 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.
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. 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. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Housing 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 South Warwickshire Local Plan area. 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 Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire. It is noted that the HEDNA has modelled new demographic projections which take account of the initial Census data releases, and seeks to assess how the population can be expected to change over time by applying more up-to-date assumptions The new trend-based projections point to a need for 4,906 dwellings annually across the sub-region which is Standard Method figure due to the recognised issues with population data which have informed previous projections for Coventry. The trend-based figures, which equate to an overall housing need across the South Warwickshire Local Plan area of 1,679 dwellings per annum is supported in principle. 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. 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. 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 3) 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.” 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 BirminghamDevelopment 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 ainto the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further.
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 Stratford-on-Avon and Warwick. The trend-based approach results in an increased housing need of 1,679 per annum. It is 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 over-estimated, 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 Lichfield’s 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 in support of 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 objectively 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.
No answer given
4.1. 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) (paragraph 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 2) 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.
4.1. 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) (paragraph 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 1) 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.
Q-H1-1 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) (paragraph 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 3) 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.
Yes, but subject to review, in light of expected changes to the planning system.
Yes, but subject to review, in light of expected changes to the planning system.
4.1. 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) (paragraph 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 1) 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.
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.
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.
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 toward a trends based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? 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 re 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.
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? 4.3 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. 4.4 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. 4.5 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). 4.6 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). 4.7 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 whilst seeking to retain the need for Stratford and Warwick suggested by the Standard Method.
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.
QH1.1 The Parish Council consider the HEDNA is a standard and tried and tested model and the Parish Council agree with using the 2021 census as the most uptodate. 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.
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.