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?
Commuting to employment completely at odds with the stated aims of a 20 minute neighbourhood principle.
No answer given
No answer given
No answer given
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 Bloor Homes 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.
No answer given
No answer given
With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include the Warwick and Leamington urban area.
It is imperative that the 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 legislation 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 imperative for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. MacMic Group consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Coventry and Warwickshire; and Greater Birmingham and Black Country. Coventry and Warwickshire 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 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 outside the Green Belt. 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 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, as required by the still-extant Duty to Cooperate. Greater Birmingham and Black Country There are also significant unmet housing needs arising from the Greater Birmingham and Black Country Housing Market Area which require consideration. 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 – 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 August to October 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 will need to engage with Birmingham and the Black Country authorities to determine an appropriate level of unmet needs to be directed to South Warwickshire, but given the scale of such unmet needs and limited scope for such unmet needs to be met elsewhere, the importance of the SWLP taking account of this should not be underestimated. 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 MacMic Group consider this is likely to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process, as a working assumption for the level of unmet need to be accommodated, the figure should be at least 10,000 dwellings.
With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, MacMic Group consider that settlements with strong sustainable transport connections and a strong functional relationship to the conurbations where unmet housing needs are arising should be prioritised. This includes at Kingswood which has a strong functional relationship with the Greater Birmingham Housing Market Area, including benefiting from Lapworth Railway Station with direct connections to a number of urban conurbations including Birmingham, and a good highway network and is located within easy reach of the M42 and M40.
No answer given
-We agree that South Warwickshire needs to contribute towards meeting the housing needs of the Birmingham and Black Country HMA. A joined-up approach is required by all the Local Planning Authorities to agree the scale of shortfall to be met by each LPA. Spatially this need should be located as close to those authorities as is feasible.
The Duty to Co-operate does make it difficult to say no this issue, but do it once and then we would be expected to do it again in years to come. We would question on how effectively they are looking at infil and brownfield sites.
As close to the area of the shortfall, with good connection.
No answer given
No answer given
No answer given
Preservation of the Green Belt is vital for health and wellbeing of the community
The unmet needs arising from within Birmingham should be agreed via a Memorandum of Understanding and allocations made to meet the unmet needs within Part 1 of the Local Plan dealing with strategic policies.
We agree that South Warwickshire needs to contribute towards meeting the housing needs of the Coventry and the Birmingham and Black Country HMA. A joined-up approach is required by all the Local Planning Authorities to agree the scale of shortfall to be met by each LPA. Spatially this need should be located as close to the authority where the need arises, or at the very least, in sustainable locations that are accessible to where the need arises. The development around the south of Warwick is a good example of how Warwick District Council has sought to meet the needs arising from Coventry close to Coventry. It may not always be practical to do that, for other reasons, but it would be in appropriate and unsustainable to locate the needs of neighbouring authorities far away from where those needs arise.
No answer given
Large developments on brownfield sites, not by eradicating the small green space areas that remain in Stratford upon Avon which support the last few remnants of wildlife in the town and allow some sort of connection via the stepping stones to connectivity which they allow.
No comment.
Not at the expense of the Green Belt.
This will only serve to increase density and add extra homes in green belt. This is about people wanting to live in a nicer area. There is enough space in Birmingham and the Black Country to support this - with better transport links (train, trams, buses).
In the major towns only.
No answer given
The green belt would need to be extended.
No answer given
look at brownfield sites in towns and vacated by commercial activity. Alternately ensure that town edge commercail and retail activity on greenfiled sites is more effectively curtailed and kept for minimal affordable housing development.
No answer given
No answer given
The sustainability of the County should come before the needs of the shortfalls of other authorities.
No answer given
No answer given
Building along railway lines into Birmingham and Coventry seems a good idea. Mappleborough Green is not an appropriate place for more housing at present, as the land to the west of the Birmingham road is a healthy woodland. Carbon storage should not be sacrificed for housing. There should be a policy to this effect in the SWLP.
Review the need via the CPRE HEDNA review paper.
PERHAPS the potential New Settlements would be the most appropriate solution to the need SWLP is finally expected to accommodate? Care would certainly be needed if significant numbers were injected into established settlements.
There is little point in producing a large overspill from Birmingham in Meon Vale/Long Marsden if it means dumping large numbers of people in an area with no infrastructure, no amenities and little scope for employment. Large quantities of cheap, mass produced boxes to place families in does not suggest a wellbeing cohesive future. More a disaster waiting to happen. The present policy of charging residents a management fee that increases with the number of residents, not diminishes, strikes of inequality with a section of Quinton/Long Marsden paying an extra element over and above their council tax for bio diverse environments enjoyed by all.
No answer given
3.30 WDC and SOADC should accommodate an appropriate proportion of the emerging GBBCHMA housing shortfall to 2040 and, once established, also accommodate an appropriate proportion of the emerging CWHMA housing shortfall. 3.31 Taylor Wimpey considers that the approach to the previous CWHMA shortfall up to 2031 was dealt with successfully through the preparation of a Memorandum of Understanding (MoU) agreed upon by each of the authorities. The MoU agreed the housing need for each authority between 2011 and 2031 and that an unmet need of 17,800 homes arose from Coventry. The MoU agreed how this unmet need was to be split between the seven authorities based on functional relationships, commuting patterns and the balance of jobs. This approach enabled all the LPAs within the CWHMA to progress their Local Plans, with the last plan adopted in June 2019. 3.32 In comparison, the approach to date by the GBBCHMA authorities has resulted in a substantial amount of Birmingham City Council’s shortfall identified in the 2017 Birmingham Development Plan (BDP) up to 2031, amounting to circa 6,000 homes remaining unaccounted for1. Indeed, the current approach has impacted timescales for plan making elsewhere in the GBBCHMA. Since Birmingham’s Local Plan was adopted in 2017 only one authority within the GBBCHMA has adopted a plan identifying any housing to meet Birmingham’s unmet needs – North Warwickshire in September 2021. The certainty provided by a strategy agreed early on by all authorities will therefore ensure that plan making can continue without delay across the GBBCHMA. 3.33 This also needs to be considered in the context of unmet needs from other GBBCHMA authorities, including the Black Country. Although the Black Country Plan has now been abandoned, the most recent version of that plan established a shortfall of circa 28,000 homes up to 2039, this shortfall is robustly evidenced through the four councils’ Urban Capacity Study Update (December 2019) and tested through the West Midlands Combined Authority Brownfield Land Study. This shortfall is based on brownfield delivery and includes Green Belt release. If there were to be no Green Belt release, the unmet need would total circa 39,000 homes. 3.34 At this stage, Taylor Wimpey do not intend to propose a model for how any unmet needs should be distributed, this is for the SWLP and HMA authorities (both CWHMA and GBBCHMA) to determine in due course, following a number of matters being resolved in the first instance. The Association of Black Country Authorities (ABCA) letter to the wider GBBCHMA authorities on 26 April 2022 sets out a very useful starting point for the GBBCHMA authorities in order to commence preparing a SoCG and it is considered that this approach would be suitable for the CWHMA too: • Review the extent of the HMA in order to understand if it represents the most appropriate geography for considering unmet needs – this is pertinent given plans from outside the HMA (i.e., Shropshire and Stafford Borough) are offering contributions to the GBBCHMA’s unmet needs. • Confirm the scale of the housing shortfall across the entire HMA over a period of at least 15 years to inform the approach to be taken. This needs to consider the remaining unmet needs from other authorities, such as the Black Country, as it may be some of the unmet need has already been met by other GBBCHMA Councils. • Review the 2018 Growth Study to understand if it remains appropriate and if there are new growth areas. This is likely to require a new study. • Review of governance arrangements between the GBBCHMA authorities in order to prepare a SoCG (an initial draft of which has been published as part of papers to Bromsgrove’s Full Council). 3.35 Whilst reviewing the 2018 Growth Study would be a useful part of any SoCG evidence base, this must be a fresh study that goes beyond the scope of the previous report and, similarly to the CWHMA and Leicester & Leicestershire HMA’s approaches, consider a model for distributing the unmet needs that goes beyond identifying growth areas. This 1 https://www.birmingham.gov.uk/downloads/file/21347/gbbchma_position_statement_adden dum_2019_to_2020_17_december_2021 10 must include detailed analysis and consideration of other models used by other HMA geographies for distributing unmet needs.
3.36 The overall contribution to any shortfall should be based on functional relationships, for example between Warwick district and Coventry, and between Stratford district and Birmingham. 3.37 Once this principle has been determined, growth should be distributed to the most sustainable locations within South Warwickshire. It is considered that by virtue of the functional relationships that exist at a strategic level, all key settlements and sustainable growth options will have strong links to the source of this shortfall.
4.10 Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes. 4.11 Issue H1 above sets out the approach to needs arising within Coventry and Warwickshire. Even under the redistribution of housing resulting from the trend-based projection, Coventry may not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. 4.12 South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. South Warwickshire is also within the Birmingham and Black Country HMA owing to Stratford-on-Avon District’s shared boundaries and interrelationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 4.13 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). One exception could be areas designated as Green Belt, particularly if such locations are deliverable, available and suitable for release from the Green Belt to deliver high quality residential developments. Locations for additional growth should be sustainable in close proximity to where people want to live. 4.14 In light of the above considerations, we 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.
4.15 Housing needs that cannot be met within neighbouring areas must be as close as possible to those areas, or within areas where sustainable transport connections can easily be made to those areas. 4.16 South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. 4.17 Southam is situated approximately 13.5 miles (21.7 km) to the south of Coventry and benefits from a direct vehicular connection to the city via the A423, which connects to the A45 and Coventry Bypass. As such, the town is ideally located to accommodate any housing shortfalls from outside of South Warwickshire, particularly Coventry. 4.18 In accordance with the guidance contained within the Framework, development should be focussed in the most sustainable locations in terms of availability of shops, facilities and services, as well as access by modes of transport other than the private car. In addition, it is considered that development should be distributed over a range of settlements rather than in single settlements in order to ensure their vitality and viability in accordance with the principles of sustainable development set out in the Framework. 4.19 L&Q Estates consider any housing shortfalls from outside of South Warwickshire should be directed to sustainable locations in accordance with the distribution of development established in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy. 4.20 Southam is identified as one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-on-Avon district. It offers a large range of shops, commercial activities such as banks, local services and facilities and pubs. Other services in the town include primary and secondary schools, a leisure centre, library, medical centres, police station and post office. There are good public transport services to the towns of Leamington Spa and Rugby, as well as community transport services that connect the town with nearby villages. 4.21 The promotion site [land east of Banbury Road, Southam] immediately adjoins the built-up area boundary of Southam and would constitute sustainable development. Indeed, it is considered that the new homes at land east of Banbury Road will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Southam’s services and facilities. Within a 10 minute walk of the site the following facilities are available: • Southam town centre (includes pubs, restaurants, bank, shops, coffee shops, takeaways, library and post office); • Petrol Station; • Tesco Superstore; • Southam Cricket Club; • Southam Football Club; • Happy Days Nursery; and • Bus Stops on Banbury Road 4.22 Primary, secondary and further education establishments and Southam Leisure Centre are all also available within a 19 minute walk. 4.23 Given the pressing need for additional housing within the Stratford-on-Avon District, in addition to meeting the housing shortfalls from outside of South Warwickshire, Southam is clearly a sustainable location to accommodate additional housing growth. The Site at land east of Banbury Road, Southam has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site would be an appropriate location to accommodate a residential development to meet housing shortfalls from outside of South Warwickshire.
62. 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 NPPF8. 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. 63. 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 64. There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. 65. 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. 66. 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. 67. 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. 68. 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. 69. 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 HLM 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 70. 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. 71. 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. 72. 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. 73. 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 releases9, 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. 8 Paragraph 35 a) of the National Planning Policy Framework (July 2021) 9 How the population changed where you live, Census 2021 - ONS https://www.ons.gov.uk/visualisations/censuspopulationchange/
74. With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should be land south of Coventry.
58. 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 NPPF8. 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. 59. 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 60. There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. 61. 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. 62. 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. 63. 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. 64. 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. 65. 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 HLM 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 66. 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. 67. 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. 68. 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. 69. 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 releases9, 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. 8 Paragraph 35 a) of the National Planning Policy Framework (July 2021)
70. With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include Southam. 9 How the population changed where you live, Census 2021 - ONS https://www.ons.gov.uk/visualisations/censuspopulationchange/
47. It is imperative that the 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 NPPF12. It is recognised that national planning policy and legislation 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 imperative for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. 48. MacMic Group consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Coventry and Warwickshire; and Greater Birmingham and Black Country. Coventry and Warwickshire 49. 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 period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. 50. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development outside the Green Belt. 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. 51. 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 leaving a shortfall of some 22,000 dwellings to be met elsewhere. 52. 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 releases13, 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, as required by the still-extant Duty to Cooperate. Greater Birmingham and Black Country 53. There are also significant unmet housing needs arising from the Greater Birmingham and Black Country Housing Market Area which require consideration. 54. 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 – a shortfall of some 78,415 dwellings. 55. 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 August to October 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. 56. 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. 57. The Councils will need to engage with Birmingham and the Black Country authorities to determine an appropriate level of unmet needs to be directed to South Warwickshire, but given the scale of such unmet needs and limited scope for such unmet needs to be met elsewhere, the importance of the SWLP taking account of this should not be underestimated. 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 MacMic Group consider this is likely to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process, as a working assumption for the level of unmet need to be accommodated, the figure should be at least 10,000 dwellings. 12 Paragraph 35 a) of the National Planning Policy Framework (July 2021) 13 How the population changed where you live, Census 2021 - ONS https://www.ons.gov.uk/visualisations/censuspopulationchange/ Conclusion on Housing Requirement 60. Bringing together all of the above, MacMic Group consider that the SWLP will need to plan for a level of housing growth as set out in the below Table 2 in the order of at least 43,000 dwellings. Table 2 - SWLP Housing Need and Supply Calculation Housing Requirement South Warwickshire Minimum Housing Need Derived from the HEDNA (1,679 x 28 Years) - 47,012 dwellings Uplift to Minimum Housing Need - TBC – further work required to determine whether an uplift is appropriate Contribution Towards Unmet Needs of Coventry and Birmingham & Black Country - TBC – engagement with Birmingham and Coventry required but suggest increase of at least 21,000 dwellings possible (circa 11,000 towards Coventry and at least 10,000 towards Birmingham) Total Housing Requirement - 68,000 dwellings + Housing Supply Sites with Planning Permission at 1st April 2022 (with 5% lapse rate applied) - 14,360 dwellings Outstanding Local Plan Allocations at 1st April 2022 - 5,579 dwellings Windfall Allowance - TBC – 4,840 dwellings assumed in line with UCS however this requires further justification / compelling evidence Total Housing Supply- 24,779 dwellings Indicative Housing Supply to Accommodate in the SWLP - 43,000 dwellings +
58. With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, MacMic Group consider that settlements with strong sustainable transport connections and a strong functional relationship to the conurbations where unmet housing needs are arising should be prioritised. 59. This includes at Kingswood which has a strong functional relationship with the Greater Birmingham Housing Market Area, including benefiting from Lapworth Railway Station with direct connections to a number of urban conurbations including Birmingham, and a good highway network and is located within easy reach of the M42 and M40.
No - South Warwickshire should not absorb the failings of other areas by to achieve investment in residential housing. Developers only want South Warwickshire for higher profit margins where housing stock achieves higher prices. South Warwickshire does not have the services & infrastructure to support. It will cost our environment and wildlife habitats. The West Midlands has lots of potential brown field sites and derelict areas which is preferable to using green belt land.
Why should we be required to meet housing shortfalls outside our area? We have a large rural area – let’s keep it before it’s lost & spoilt forever. The UK needs land for agriculture, farming and wildlife. Why move the urban sprawl to spoil virgin land?
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
No answer given
As part of the Housing Market Area (HMA) for Birmingham and Black Country, Terra believe that is wholly appropriate for South Warwickshire to contributed to the identified shortfall. Birmingham alone has a reported shortfall of c. 78,000 dwellings. The Country is currently in a housing crisis, and substantial unmet need coming out of large cities such as Birmingham should be met in neighbouring authorities where possible.
Terra believe that the shortfall could be met in a combination of ways. This could be accommodated in new settlements as well as areas on the urban edge, to provide existing and future residents with a range of choice. Any housing numbers set within the Local Plan should also be set as a minimum figure to ensure flexibility and this will also allow the Plan to react to future demand.
No answer given
As part of the Housing Market Area (HMA) for Birmingham and Black Country, Terra believe that is wholly appropriate for South Warwickshire to contributed to the identified shortfall. Birmingham alone has a reported shortfall of c. 78,000 dwellings alone. The Country is currently in a housing crisis, and substantial unmet need coming out of large cities such as Birmingham should be met in neighbouring authorities where possible. Terra believe that the shortfall could be met in a combination of ways. This could be accommodated in new settlements as well as areas on the urban edge, to provide existing and future residents with a range of choice. Any housing numbers set within the Local Plan should also be set as a minimum figure to ensure flexibility and this will also allow the Plan to react to future demand.
South Warwickshire should under no circumstance choose to take more additional growth, this would put additional serious pressure on services, infrastructure, important habitats and environments in the area. The other Councils need to legitimately look to find land/ increase housing densities in their local areas. Especially as it would appear Birmingham has copious brown field sites which could be utilised which would be preferable to using green belt land. Under no circumstance should Warwickshire take on the shortfall off other areas.
We should not and appropriate strong objection is needed against this. If Stratford Council fails in this and is forced then more high quality duplex flats should be built with decent sound proofing, balconies, roof terrace/garden space. As we do not have enough land in the UK to allow for agriculture, wild space and enough housing we need to be utilising our air space more. Flats would be more desirable in the UK if they were built properly. We can not continue with everyone’s wish for a 4-bed detached house with a garden. There is not enough room.