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?
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 . The two likely sources of unmet needs are from Birmingham and Black Country and Coventry and Warwickshire. The level of unmet need in Birmingham and the Black Country is circa 78,415 dwellings and there are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA. Coventry is highly constrained by a tightly drawn administrative boundary with potential for brownfield redevelopment but limited opportunity for greenfield development. It is highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Given the functional relationship that exists, the Councils should engage with the relevant local authorities to determine an appropriate level of unmet needs to be directed to South Warwickshire.
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Agree. This is an essential area of cross-boundary co-operation and an active element for the Duty to Co-operate. The Plan should clearly identify and reflect the current commitments included within existing adopted Local plan. This commitment be included/reflected as part of the current need in addition to any emerging need, and the approach used as part of the legal requirement in the Duty to Co-operate (as part of the wider GBBCHMA and CWHMA work) to continue in order to address future need, Base the accommodation on evidence of travel to work/commuting patterns to provide a true reflection of relationship with GBBCHMA. No further comment.
Incorporate the shortfalls as an integral part of the Plans overall housing requirement, to be provided within the Plans overall settlement site allocations or similar. Advisable to avoid specific site allocations/identification to address the shortfall to be accommodated. No further comment.
No - nor any Coventry shortfall in Warwick district (why has this question not been asked?). New Ministerial guidance suggests any overspill to adjacent authorities will not be obligatory - especially it would seem when it would require encroachment on the Green Belt. Greater intensification of land use - building up and improved designs - are one way forward. Another is for both conurbations to question and remove the arbitrary 30% added to their identified local needs by central government, far ahead of past population and household trends. They like all LA's are now being given the flexibility to do so if local circumstances justify. They probably also face the twin challenges of catching up with unmet social housing needs and zero carbon retrofitting within their own communities, rather than adding to urban sprawl and commuting in adjacent areas.
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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 support employment and the economy. If there is a need for additional housing it should sensitively contribute to local economic growth. In the Green Belt and rural areas they should be required to maintain a rural link 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.
It will be used as an easy excuse for not placing developments within the area where they are required and increase commuting.
This approach should be resisted or redirected to authorities better suited to meet these needs.
The shortfall should be accommodated by sites which minimise transport for jobs, etc. to be sustainable. Stratford-upon -Avon, and particularly East of the river, is located at almost the furthest distance from the jobs, and providing any transport infrastructure to these locations will be uneconomic and be detrimental to the climate pledge.
The locations should be as close as possible to the area generating the loss, and able to provide sustainable transport connections to the job area.
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 Rosconn Strategic Land 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 releases , 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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This seems to fly in the face of sustainability principles.
As close to the boundary with those outside areas as possible.
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There are huge areas of derelict/poor housing and waste land in West Midlands (Bham and Black Country) which could be used. Area needs redevelopment. Such a strategy as H4-1 would increase traffic and impact environmental aims.
I don't see why there should be such a need. There are plenty of sites within Bham and Black country that could be used with some imagination, and would contribute to improving the area. They have better transport infrastructure.
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Alongside existing larger developed areas or a new single large development.
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If sites are not released from the Green Belt to meet housing needs from the Black Country towns to the north, then more people will search for property in the areas where new housing is being built outside the Green Belt. This results in more development leap frogging the Green Belt and more long distance commuting. There is evidence that many people are moving to Meon Vale and commuting to the Black Country towns and beyond.
THERE SHOULD BE A REALISTIC PLAN ON THE SHORTFALL BEARING IN MIND THE NEED OF ADEQUATE INFRASTUCTURE REQUIREMENTS
HAVE INSUFFICIENT KNOWLEDGE ON THIS
As little as possible - it's akin to rewarding failure and penalising those areas that over achieve on their targets.
Areas where higher volumes of dwellings can be built. The size of the problem seems to be significant (in the tens of thousands) and the current approach of small scale development is like death by a thousand cuts with our areas being destroyed piece by piece rather than a big bold decision being made.
The Green Belt around Kenilworth, Warwick, Leamington and surrounding villages is constrained by a severe lack of green space which separates these communities. Any further erosion into this precious space from Birmingham or Coventry overspill would be catastrophic. Do we really want one huge conurbation where all these communities lose their identity into an amorphous new cityscape? The area has already been damaged by HS2 and its biodiversity and sustainability severely compromised. There are major brownfield sites throughout the West Midlands which offer better alternatives.
These should fill in brownfield sites and then stay close to major conurbations from which the problem emerged.
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Although we have a Duty to Co-operate, I feel that we should not be required to accommodate the shortfall, do it now and S.W. would find it difficult to say no in the future. Are all brownfield sites, empty offices in B'ham been considered for housing?
As suggested, near to the area of the shortfall and with good connection to that area.
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Please do not build anything on our green belt/green spaces. This development must stop. We must start protecting our landscape and habitats. Surely this needs revisiting.
Please do not build anything on our green belt/green spaces. This development must stop. We must start protecting our landscape and habitats. Surely this needs revisiting.
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each area have different outlook on their housing strategy which most likely than not won't align with one another.
closer to the boundary
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See response to QH1-2 which included the possible removal of the duty to cooperate.
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I do not believe it is appropriate to consider that housing shortfalls in Birmingham and the Black Country can realistically be met in South Warwickshire. This is not because of lack of available space in South Warwickshire, but the obvious point that developing housing in South Warwickshire as a proxy for Birmingham or the Black Country flies in the face of promoting sustainability e.g. local jobs, local transport etc.
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NPPF point 141 states that use of Greenbelt for development should only be considered where use of brownfield sites and underutilised land has been fully explored. Evidence that Birmingham and Black Country have fully explored not seen. Evidence that South Warwickshire have fully explored not seen.
See above.
If shortfalls are absorbed from other areas, where is the incentive to meet targets in the future? And ultimately some areas would benefit (the ones that had the shortfall) and some areas would suffer (the ones that met the targets). Therefore the amount of shortfall absorbed should be zero, and an imaginative large scale solution should be reached that falls within the areas that have yet to meet their targets.
An historical town like Stratford-upon-Avon should not be ruined because of shortfalls outside of South Warwickshire. If it came to it, areas could be chosen where higher volumes of dwellings could be built rather than filling in several small pieces of land.
THIS CONSULTATION SHOULD REFER TO THE CONSULTATION RESPONSE MADE TO THE 2022 SITE APPRAISAL CONSULTATION ISSUED BY SDC.
THIS CONSULTATION SHOULD REFER TO THE CONSULTATION RESPONSE MADE TO THE 2022 SITE APPRAISAL CONSULTATION ISSUED BY SDC.
The area shouldn’t choose to take more extra additional growth, this would put additional serious pressure on important habitats and environments in the area. The other Councils need to legitimately look to find land/ increase housing densities in their local areas.
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