Q-H4-1: Do you agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-on-Avon District?
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There are so many brownfield sites in this area that although more difficult than a nice undeveloped field they are so much more worthy of development for both biodiversity and general character
Those shortfalls should only be accommodated within brownfield sites.
We welcome the acknowledgement that Stratford-on-Avon falls within the Greater Birmingham and Black Country Market Area (GBBCHMA) and the recognition that homes built within the district can contribute to the GBBCHMAs unmet housing needs. We welcome the positive approach taken to date in respect of seeking to address the housing shortfall arising from the GBBCHMA. Under the Duty to Cooperate, we continue to support ongoing joint working with the South Warwickshire authorities to address the GBBCHMA housing shortfall going beyond 2031 and up to the end of the South Warwickshire Local Plan (SWLP) period of 2050. The approach of identifying reserve sites within Stratford-on-Avon that contributes towards the housing shortfall of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) up to 2031 is welcomed. It is understood that these sites, if adopted via the Site Allocations Plan for Stratford-on-Avon, will carry forward into the South Warwickshire Local Plan. The consultation SWLP refers to the recent Birmingham Local Plan Issues and Options consultation (2022) which identifies a significant potential shortfall of 78,415 homes. It states that there may be additional housing shortfalls arising from the Black Country authorities. Whilst the Black Country authorities have recently agreed to cease work on the joint Black Country Local Plan (October 2022) it should be recognised that the most recent consultation on the plan (Regulation 18, Draft Plan in Summer 2021) did identify a significant housing shortfall of 28,239 homes for the period 2020-2039. The scale of the potential shortfall should therefore be recognised. Whilst the approach taken to date in respect of reserve sites identified in Stratford-on-Avon for unmet housing needs up to 2031 is supported, we consider that the approach taken in the SWLP going forward (up to 2050) should reflect the potentially significant scale of the GBBCHMA shortfall (noting that this is subject to further evidence base work as part of the Local Plan process for the GBBCHMA partner authorities.) We note that the SWLP refers to the accompanying Sustainability Appraisal testing options of an additional 5,000 and 10,000 homes for unmet housing needs. At page 109 of the SWLP, it states that given the size of South Warwickshire it is considered that any additional needs can be accommodated outside of any protected areas (e.g., Cotswolds National Landscape/AONB) with one exception possibly being areas designated as Green Belt.
It is noted that the ‘refined’ spatial options for growth include those focused on sustainable transport corridors (rail and bus) and areas for economic growth. Within these options there is the potential for the delivery of new settlements. In respect of helping to address the GBBCHMA housing shortfall, we consider that development in the most sustainable locations which provides sustainable commuting links to the wider conurbation would be appropriate. We consider that new settlements would also be appropriate, as they would generate a significant scale of housing with associated employment uses, justifying significant infrastructure and transport improvements including new and improved commuting links. We consider that development in and around those locations that are or could be major sources of employment in South Warwickshire would also be appropriate as it could provide a balance of homes and jobs and reduce the need to travel.
The needs arising from the BBCHMA are increasing and there MUST be sufficient flexibility in the SWLP to meet these future needs. The issue is that the BBCHMA and surrounding Local Plans are always out of sync so the Local Plans are always playing 'catch-up' and thus placing unnecessary pressure on the BBCHMA needs. The way round this is to accept that housing needs are only going to increase and thus to make a positive and theoretical 'over provision' in the Local Plan - noting that this includes a (quantified) allowance for future needs not yet defined/agreed.
Extensions to more existing settlements (such as Hockley Heath which is probably THE best placed settlement, with an excellent range of services, facilities and connectivity) to meet the needs of the BBCHMA. C?onsideration should also be given to the extension of Shrewley/Rowington in the form of a new village with its excellent links to established services/facilities and connectivity (to the Warwick Parkway station nearby).
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THIS SHOULD BE A REALISTIC FIGURE REGULARLY UPDATED
NEAR RAIL AND MAIN ROADS IN VILLAGES/TOWNS WHO HAVE OR CAN HAVE GOOF ADEQUATE FACILITIES WITH A REALISTIC REVIEW OF BROWNFIELD AND GREEN BELT AREAS
WE need to meet local needs first.
New settlement, not Green Belt
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We need to maintain the green open space in this county
In existing towns - rather than new settlements
The existence of derelict and brownfield sites across Birmingham and Black Country, managed effectively, would be sufficient to cater for the needs of those areas for decades. Not only does Stratford not have such land available, the sites earmarked would degrade the local environment if developed. For example, site STR.C has twice been the subject of refused planning applications due for many reasons, including wildlife habitat and historical significance. Not only this, but with the existing development overkill in Stratford, the road and other infrastructure is at breaking point already. What was once a pleasant market town has already been turned into a litter strewn, shabby, unsafe one without making it even worse by building over the few green spaces left.
You shouldn't. The authority should grow some and fight to protect the area rather than willingly run towards becoming a suburb of Birmingham.
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South Warwickshire has already met a significant housing shortfall from other neighbouring locations and should resist further allocations.
The SWLP should co-operate with neighbours and help to meet the needs of Birmingham and the Black Country. Doing so will bring significant economic, environmental and social benefits to the area. Not doing so will be to the disbenefit of South Warwickshire, Birmingham and the Black Country.
The shortfalls should be met as part of the approach to Spatial Growth - most appropriately in extensions of up to 2500 homes to the most sustainable existing settlements in the area. These are the settlements in accessible locations with railway stations and with scope to expand employment provision alongside enhancements to biodiversity, heritage, community and so on. The Henley-in-Arden Vision document demonstrates how this can be achieved in an appropriate manner.
Birmingham has more than enough space to provide the housing needs of it's population. There are large plots of undeveloped brown field sites which can be developed which although would have a higher construction cost that green field development would quickly become a more sustainable option as the people would live by where they work and can access the facilities they need.
On brownfield sites.
It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF. It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above William Davis consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases10, an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.
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The smallest amount possible should be included within this plan- it should not be our responsibility to make up for shortfalls elsewhere, especially at the expense of losing greenbelt land
Outside the greenbelt- to the south of the area to which this plan relates, with Warwick DC and Stratford DC areas both contributing. Greenbelt land should not be considered for development of any type, let alone to meet shortfalls from other areas
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Coventry City Council has just begun a Local Plan review. We are undertaking a housing capacity study and will work on a continual basis with our partners in South Warwickshire as part of the well-established culture of joint working and as part of the Duty to Co-Operate requirements. We welcome the inclusion of this subject in the SWLP and look forward to on-going joint working.
Accommodating shortfalls provides an avenue for avoiding the recycling of industrial and brownfield sites within the greater West Midlands conurbation and encourages the extension of urban sprawl into precisely the area designed to (i) contain it and (ii) encourage sustainable and responsible land use.
Government Policy states that it is not necessary to review and release Green Belt land at all. It is a vital resource which is currently undervalued in the SWLP. Releasing land from Green Belt in South Warwickshire to meet housing shortfalls elsewhere creates a false supply as well as irreversible harm to the Green Belt which would set a precedent for continued erosion whenever the need arises. Housing shortfalls should first be directed within the boundaries of the areas within which they are expected to service employment and economy. If further housing needs are required, they should sensitively contribute to local economic growth. In reference to Green Belt and rural areas they should be required to maintain a rural link to encourage rejuvenation of local character and contribute to the future stewardship of those areas or protect their heritage. Expansion of the conurbation would have significant detrimental impacts on the character, environment, biodiversity and national contribution to food production of these areas.
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This approach provides an avenue for avoiding the recycling of industrial and brownfield sites within the greater west midlands conurbation and encourages the extension of urban sprawl into precisely the area designed to contain it and encourage sustainable and responsible land-use.
Such shortfalls should first be directed within the boundaries of the areas within which they are expected to service employment and economy. If further housing needs are required, they should sensitively contribute to local economic grown. In reference to greenbelt and rural areas they should be required to maintain a rural link to encourage rejuvenation of local character and contribute to the future stewardship of those areas o protect their heritage. Expansion of the conurbation would have significant detrimental impacts on the character environment, biodiversity and national contribution to food production of these areas.
Shipston on Stour is located too far South of the area to be of any value for meeting any shortfall in Birmingham or the Black Country.
As close as possible to the area of shortfall. Located on rail routes or regular bus routes.
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There are many brownfield sites within Birmingham and Black Country boundaries that should be used in the first instance.
Add to existing conurbations. Green belt land should not be used.
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Initially account should be taken of sites included in the present Local Plans but where development has not yet begun, so the numbers of dwellings already proposed on those sites should contribute to future needs that may be identified (but not based on ONS 2014 projections). For example, in the area denoted as South of Coventry — where BGPC believes the currently ‘safeguarded’ land south of Westwood Heath Road should be returned to the Green Belt — there is a substantial area known as Kings Hill included in the 2017 Warwick Local Plan to accommodate up to 4,000 homes, and on which outline permission for 2,500 has already been granted, but where no work has commenced. Given the previous excessive and erroneous projections for Coventry’s population growth, this land should be more than adequate to contribute to any further excess Coventry requirements in the foreseeable future. Furthermore, Burton Green PC has been advised that Coventry has sufficient brownfield sites to meet its expected needs up to 2031.
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Housing shortfalls from outside of South Warwickshire should be met at sustainable locations, which contribute towards creating and sustaining strong communities. Radford Semele is highly sustainable given its proximity to Leamington Spa. The settlement also is not constrained by Green Belt. The land at Radford Semele is in a prime position to accommodate housing growth, assisting in the objective to meet shortfalls from outside of the SW area. We are supportive of SW meeting unmet needs from Birmingham, and support that housing targets should be reflective of this additional need. This will and should, in turn, as a result boost the delivery of affordable housing, along with a wider range of housing.
I don't think there is a shortfall. My daughter lives and works in the Black Country. Commuting from Warwickshire is not a good option, she has already tried it. Poorer returns for builders compared with other areas is the problem that contributes to the shortfall in Birmingham and the Black Country.
We should emphatically refuse.
2.10 The SWLP area sits alongside other HMAs, most notably the Birmingham and Black Country HMA. As is set out under Issue H4 Birmingham has commenced work on a new Local Plan and the housing needs work has suggested a shortfall of 78,415 homes. In addition, it is noted that the Black Country authorities recently announced that they were abandoning the joint working that had taken place on the Black Country Core Strategy and would now pursue individual local plans. It seems likely that this work will also reveal a shortfall in housing land to meet needs of those authorities. As set out above, it would seem likely that the scale of need now to be met in Coventry would lead to much reduced levels of unmet need, if at all. 2.11 The Consultation Document makes clear that the SWLP is likely to be able to make provision for some of the unmet need from Birmingham and the Black Country. Given the lack of constraints in parts of the plan area this approach is supported. Clearly the level of unmet need arising in Birmingham and the Black Country is yet to be crystallised through their respective plan making processes, and the amount of unmet need that the SWLP may be asked to accommodate cannot be known. The approach taken of testing 5000 – 10000 new homes to be accommodated by 2050 therefore seems to be a reasonable approach to understanding the implications of accommodating unmet need. 2.12 We would, however, note that it is not possible to say at the current time whether this level of unmet need bears any resemblance to what may be required. Given that the SWLP plan period seems to be 2021 – 2050 – a timespan of 29 years – the level of unmet need being tested amounts to 172 dpa – 344 dpa. These are significant increases but without an agreement with the Birmingham and the Black Country authorities, and the other LPAs in the HMA it is not possible to know whether this level is sufficient over time. Therefore, we will reserve a position on whether this is an appropriate response until later plan making stages.
2.13 In response to Q-H4-3, we would simply say that whatever spatial strategy is chosen to distribute housing across the SWLP area, should be capable of accommodating housing needs in a sustainable manner which ensures that the needs of communities across the plan area are met. If the spatial strategy cannot accommodate the plan requirement, including any element of unmet need, the spatial strategy will need to be re-thought to ensure that the requirement can be met in full. In order to make this judgement, it will be necessary for the SWLP Parts 1 and 2 to bring forward sustainable sites for housing development that can contribute to the sustainability and vitality of communities, and we would suggest that the land at Roger’s Lane, Ettington is one such site.
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We should accommodate such shortfalls near transport routes especially if people commute to their workplace.
South Warwickshire has enough of its own shortfall in affordable housing, local facilities eg Doc's, schools, etc without having to accommodate people from maybe 25-30 miles away who will then have to travel long distances to work.
Don't agree that South Warwickshire should meet ANY shortfalls from outside the area.
Surely Birmingham & the Black Country have got lots of Brownfield sites that could be used.
We should not be accommodating the housing shortfall outside South Warwickshire, this would promote more commuting by car as the occupants will be working outside of South Warwickshire and there is no satisfactory public transport or infrastructure to accommadate this commuting.