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?
Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a staggering shortfall in housing of 78,415 homes, with additional shortfalls potentially identified from the Black Country authorities. There remains to be an agreed and co-ordinated approach to addressing unmet needs around Birmingham so the SWLP should consider accommodating some needs having regard to, inter alia, the functional relationship between the South Warwickshire and the source of these shortfalls. It is noted that for the purposes of the SA the Councils have tested the effects of an additional 5,000 and 10,000 homes, which we support in principle. However, further engagement and agreement with neighbouring authorities is required and any level of unmet need planned to be accommodated must also be subject to a future review, pending the outcome of any wider work to comprehensively address unmet needs in the region.
No answer given
St Philips welcomes South Warwickshire’s acknowledgement of the need to help meet the unmet needs of the C&WHMA and the GBBCHMA. The IO states: “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. However, South Warwickshire is also within the Birmingham and Black Country HMA… Through the duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs” (page 111). 2.87 In this regard, St Philips notes that within the GBBCHMA there is emerging evidence of an acute level of unmet housing needs. Birmingham City Councils New Local Plan 2020-2042- Issues and Options (“BCCIO”) has recently confirmed that, as of March 2022, Birmingham’s LHN figure is 7,136 dpa (Para 4.7). This includes an additional 35% for the top 20 largest cities in the UK. 2.88 Cumulatively, this would equate to a housing need figure of 149,286 dwellings for the 22-year plan period (2022 to 2042). The BCCIO states that the Council can currently demonstrate a supply of 70,871 dwellings, which includes completions between 2020/21- 2021/22 of 6,624 dwellings. The BCCIO concludes that, at present, there is a shortfall of around 78,415 dwellings to be found through the preparation of the BDP Review (Para 4.15). 2.89 Alongside Birmingham’s emerging unmet needs (c.78,000), another significant source of potential unmet needs is from within the Black Country. It is important to note that the Black Country Plan is no longer being jointly prepared and thus the Black Country Authorities will now prepare individual Local Plans; however, it is highly likely that the unmet need for housing c.28,000 dwellings still remains in the Black Country; albeit, now disaggregated amongst the four Black Country Authorities. As such, the level of unmet housing needs in the GBBCHMA is likely to be severe. St Philips acknowledges that Coventry’s need has been reduced from 3,188 dpa as per the 2014-based projection to 1,964 dpa as per the trend-based projection. Although, it is important to note that an updated housing trajectory has not yet been released for Coventry meaning that the unmet need is yet to be calculated. It is highly likely that South Warwickshire will need to accommodate part of this unmet housing need. Given that Coventry has a very small amount of land that is outside of the urban area and free from constraints (equating to c.2% of the authority’s area) St Philips consider that it is extremely likely that Coventry will require further assistance in meeting its housing needs post-2031. 2.91 In this context, paragraph 11b of the NPPF is clear that: “b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: (i) the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or (ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole” 2.1 In this regard, the IO recognises that “given the size of South Warwickshire it is considered that any additional needs can be accommodated outside of any protected areas” (Page 109). The exception to this is noted to be areas within the Green Belt, however these sites would only be considered if suitable, appropriate, and necessary. St Philips considers that areas like South Warwickshire with such a large quantum of available land have a duty to support housing growth and not only address its housing need, but also the shortfall of housing provision within surrounding authority areas. 2.2 Whilst St Philips acknowledges that it is not for South Warwickshire to address these unmet needs in full, given the scale of the shortfall arising from the GBBCHMA, St Philips considers that South Warwickshire must play a significant role. It is important that South Warwickshire makes it clear that it will help address the acute unmet need and should, where possible, be specific in the exact proportion of the unmet need that the upcoming Local Plan can accommodate. 2.3 Indeed, this is particularly pertinent, given the Inspector’s recent findings11 in respect of the Sevenoaks Local Plan where problems of unmet need were not adequately addressed through the duty to cooperate process, resulting in a terminal failure of legal compliance. Unless a proportionate contribution towards the unmet needs identified is accommodated, South Warwickshire risks not fulfilling its ‘duty to cooperate’ with neighbouring authorities, as required by paragraph 24 of the NPPF. St Philips supports South Warwickshire’s acknowledgement of the Duty to Cooperate but also recommends that a proportionate contribution should be made to ensure that the emerging Local Plan can pass the test of soundness. St Philips consider that a functional relationship approach is a suitable strategy and refers to Lichfields’ ‘The Black Country’s next top model’. Lichfields’ model drew on the precedent set in the Coventry and Warwickshire HMA/North Warwickshire and has been again supported by the emerging approach in the Leicester and Leicestershire HMA. Both Stafford Borough Council and South Staffordshire Council reflected on Lichfields’ model in the latest sustainability appraisals for the current consultations, St Philips therefore encourages South Warwickshire to adopt Lichfield’s model in order to sustainably distribute Birmingham’s and Coventry’s unmet housing need. 2.5 The model calculates the proportion of housing that can be sustainably redistributed towards surrounding authorities based on the functional relationship between the administrative areas. 2.6 Such a model takes account of the below trends within the HMA and between authorities with a functional relationship: 1 Migration patterns between authorities; 2 Commuting linkages between authorities; 3 Opportunities to capitalise on sustainable transport links; 4 Affordability pressures; and 5 The degree of environmental and physical constraints. 2.7 The objective should be to create an agreed position with regard to the spatial distribution of housing that is justified based upon technical evidence and which can be used to underpin the preparation of Local Plans. 2.8 This would ensure that as and when a spatial distribution methodology is agreed, South Warwickshire will have in place a sufficient supply of sites which have been tested through an acceptable model and other evidence base documents.
As set out above, St Philips considers that it is imperative that the SWLP assists with meeting the acute housing needs of South Warwickshire’s neighbouring authorities. Given the scale of the unmet need, St Philips considers that there is a need to review the Green Belt within the district. In this context, St Philips welcomes the IO’s recognition that: “A review of the Green Belt across South Warwickshire is an important piece of evidence to underpin the approach taken in the Local Plan. It would consider whether there are any areas which no longer meet all five of the Green Belt purposes and could be removed to allow for the most sustainable development to come forward, including the provision of affordable housing and employment opportunities.” (IO, page 57). 2.10 St Philips is highly supportive that the IOs approach has been ‘blind’ to whether a particular location or corridor is in the Green Belt. This approach ensures that sustainable locations within the Green Belt are not prematurely excluded from consideration. The IO recognises that: “The location and spread of the Green Belt in South Warwickshire may mean that limiting growth to locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option as it pushes development away from areas that are well connected with good infrastructure and better access to facilities and services towards areas with more limited infrastructure and where further travel would be necessitated” (page 56). 2.11 Notwithstanding the above, St Philips acknowledges that the NPPF is clear of the weight attached to the Green Belt by the Government, and that “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.” (Para 140). The NPPF sets out that prior to considering whether “exceptional circumstances” exist, local planning authorities should have “demonstrated that it has examined fully all other reasonable options for meeting its identified need for development” and goes onto provide a set of criteria that should be satisfied prior to establishing exceptional circumstances (e.g. a sequential approach of sorts) (Para 141). These include (inter alia) the optimisation of brownfield land, densities and discussions with neighbouring authorities. 2.12 In this regard, the Urban Capacity Study (October 2022) “has established that it is unlikely to be possible to meet currently development needs without significant greenfield development” (Urban Capacity Study, Page 1). There is also a significant, and persistent level of unmet housing need across the GBBCHMA and many of the Council’s neighbouring authorities are already unable to meet their own needs within existing urban areas. 2.13 In establishing the “exceptional circumstances” required to review the Green Belt, St Philips consider that the Council should also have regard to the acuteness of the unmet housing needs within the GBBCHMA, which might reasonably be considered an ‘exceptional circumstance’. Indeed, in the Calverton Parish Council v Nottingham City Council High Court Judgment12, the Judge pointed to the acuteness of the objectively assessed housing needs when considering whether housing need should be considered an exceptional circumstance (Para 51). 2.14 As such, St Philips considers that the acuteness of the unmet housing need arising from the Birmingham HMA can, and in this instance, should, constitute exceptional circumstances, as established in the Calverton case. It is therefore entirely reasonable, and indeed necessary, for the Council to review the Green Belt within the District, to help meet the needs of South Warwickshire and its surrounding neighbouring authorities.
6.1 This approach was determined through the Stratford Site Allocations Plan (“SAP") which is still in draft format and yet to receive the scrutiny of a Local Plan Inspector, as such only limited weight can be given to this strategy at present. 6.2 In any event, the sites identified in Stratford-on-Avon District are to address needs until 2031 based on unmet needs that existed at the time. The SWLP covers a period well beyond this and Birmingham City Council has also commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a staggering shortfall in housing of 78,415 homes, with additional shortfalls potentially identified from the Black Country authorities. 6.3 Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a staggering shortfall in housing of 78,415 homes, with additional shortfalls potentially identified from the Black Country authorities. 6.4 There remains to be an agreed and co-ordinated approach to addressing unmet needs around Birmingham so the SWLP should consider accommodating some needs having regard to, inter alia, the functional relationship between the South Warwickshire and the source of these shortfalls. It is noted that for the purposes of the SA the Councils have tested the effects of an additional 5,000 and 10,000 homes, which we support in principle. However, further engagement and agreement with neighbouring authorities is required and any level of unmet need planned to be accommodated must also be subject to a future review, pending the outcome of any wider work to comprehensively address unmet needs in the region.
6.1 It is noted that there is no specific question regarding Coventry’s potential unmet needs but given the significant affordability issues and the likely requirement for an uplift to the trend-based approach, we consider that it is likely that there will be unmet needs to be addressed in the SWLP. 6.2 Whilst the distribution of unmet needs will be a matter for the respective LPA’s to address, the identification of specific strategic sites to assist with meeting unmet needs is considered to be a robust approach as it ensures sufficient sites are actually identified to meet this need and that these are in appropriate locations. It is clear, given its relationship with Coventry, that Westwood Heath is strategically well located to assist with meeting any unmet need from the Coventry as well as assisting with addressing the unmet need from the wider region from places such as Birmingham.
The housing need within the Greater Birmingham and Black Country HMA is still under review, following the halting of the joint Black Country Local Plan. The Black Country authorities are currently reconsidering their housing needs and how this will impact on the wider HMA. In light of this, the significant housing shortfall identified by Birmingham City Council, and the likelihood that Coventry will not be able to accommodate all of its housing needs (even at the reduced trend-based level of 1,964 homes per annum), the South Warwickshire authorities will need to meet some of the unmet need from these areas. It is noted that page 109 of the Issues and Options consultation document highlights that there is a strong argument that if homes are being provided to meet needs arising in Coventry and Birmingham then those homes should be located as close as possible to the source of those needs in order to minimise travel, or close to good transport connections to these areas. Particular emphasis should be placed on locations for this development that have sustainable connections to employment opportunities across the HMAs. There is a need for the South Warwickshire Councils to continue to monitor the housing capacity studies being undertaken in the Birmingham and Black Country HMA and by Coventry City Council to assist with identifying what appropriate contributions it might need to make to assist with meeting the unmet need.
Links with Coventry City arise through commuting patterns, as well as the physical location of Warwick District on the edge of the Coventry built up area. The relationship with the Birmingham and Black Country HMA is intrinsically linked to the migration / commuting patterns. Good connectivity with the primary transport infrastructure in both instances is important, notably in relation to the sustainable travel infrastructure to provide access to the relevant, employment, leisure and community facilities both within this external HMA and within the SWLP area. Sites for housing development should be located where this can be achieved. The appropriate Growth Options would be Growth Option 1 and 2. As identified in response to Issue 6 (Green Belt) under QS-10, and in response to the identified spatial growth options, a spatial distribution strategy which capitalises on opportunities provided by the existing sustainable transport network, as well as providing good connectivity between homes and employment opportunities in main towns, is important. Locations that can achieve this through existing sustainability credentials, or can be made more sustainable through additional development should be considered for allocation. This should include appropriately located land in the Green Belt. In this regard, sites should be allocated in close proximity to existing railway stations (notably including Warwick Parkway) in order to deliver residential development to meet the needs of the SWLP and / or any additional unmet need arising from outside of the SWLP boundary.
It is not clear from the Options document how many dwellings South Warwickshire is likely to be expected to accommodate. It is also not clear how SW officers will input into other area’s plans to ensure emphasis is placed on brownfield development rather than on other criteria. There is a lot of brownfield land within Birmingham and the Black Country. Priority should be given to addressing the needs of South Warwickshire in the first instance and ensuring that this is done in the most appropriate locations rather than just focusing on the need to accommodate unmet need as closely as possible to those areas in a blunt way. We do not agree that simply focussing on rail networks is an appropriate strategy as this is slow, inflexible, subject to a myriad of external pressures will soon be superseded by innovations in sustainable transport allowing a much more dispersed and diverse approach.
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 IM consider that 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 The CWHMA approach has been much more successful in ensuring the identified shortfall has been met, when compared to the Birmingham City Council (BCC) shortfall UP TO 2031 which was identified in the 2017 Birmingham Development Plan (BDP). The approach to date by the GBBCHMA authorities has resulted in a substantial amount of BCC’s shortfall identified in the 2017 BDP, amounting to circa 6,000 homes remaining unaccounted for. The GBBCHMA approach has impacted timescales for plan making elsewhere in the MA. Since Birmingham’s 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 and CWHMA. 3.33 This also needs to be considered in the context of unmet needs from other HMA 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 WMCA Brownfield Land Study. 3.34 IM consider that 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: • Reviewing 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. • Reviewing 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, we are of the view this must be a fresh study that goes beyond the scope of the previous report and, similarly to the previous CWHMA approach, consider a model for distributing the unmet needs that goes beyond identifying growth areas. This 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 with WDC and Coventry, and between Stratford and Birmingham. Once this principle has been determined, growth should then be located in the most sustainable locations within WDC and SDC. 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.
St Philips welcomes South Warwickshire’s acknowledgement of the need to help meet the unmet needs of the Coventry and Warwickshire Housing Market Area [C&WHMA] and the GBBCHMA. The IO states: “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. However, South Warwickshire is also within the Birmingham and Black Country HMA… Through the duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs” (Page 111). In this regard, St Philips notes that within the GBBCHMA there is emerging evidence of an acute level of unmet housing needs. Birmingham City Councils New Local Plan 2020-2042-Issues and Options [BCCIO] has recently confirmed that, as of March 2022, Birmingham’s LHN figure is 7,136 dpa (Para 4.7). This includes an additional 35% for the top 20 largest cities in the UK. Cumulatively, this would equate to a housing need figure of 149,286 dwellings for the 22- year plan period (2022 to 2042). The BCCIO states that the Council can currently demonstrate a supply of 70,871 dwellings, which includes completions between 2020/21- 2021/22 of 6,624 dwellings. The BCCIO concludes that, at present, there is a shortfall of around 78,415 dwellings to be found through the preparation of the BDP Review (Para 4.15). Alongside Birmingham’s emerging unmet needs (c.78,000), another significant source of potential unmet needs is from within the Black Country. It is important to note that the Black Country Plan is no longer being jointly prepared and thus the Black Country Authorities will now prepare individual Local Plans; however, it is highly likely that the unmet need for housing c.28,000 dwellings still remains in the Black Country; albeit, now disaggregated amongst the four Black Country Authorities. As such, the level of unmet housing needs in the GBBCHMA is likely to be severe. St Philips acknowledges that Coventry’s need has been reduced from 3,188 dpa as per the 2014-based projection to 1,964 dpa as per the trend-based projection. Although, it is important to note that an updated housing trajectory has not yet been released for Coventry meaning that the unmet need is yet to be calculated. It is highly likely that South Warwickshire will need to accommodate part of this unmet housing need. Given that Coventry has a very small amount of land that is outside of the urban area and free from constraints (equating to c.2% of the authority’s area) St Philips consider that it is extremely likely that Coventry will require further assistance in meeting its housing needs post-2031. In this context, paragraph 11b of the NPPF is clear that: “b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole” In this regard, the IO recognises that “given the size of South Warwickshire it is considered that any additional needs can be accommodated outside of any protected areas” (Page 109). The exception to this is noted to be areas within the Green Belt, however these sites would only be considered if suitable, appropriate, and necessary. St Philips considers that areas like South Warwickshire with such a large quantum of available land have a duty to support housing growth and not only address its housing need, but also the shortfall of housing provision within surrounding authority areas. Whilst St Philips acknowledges that it is not for South Warwickshire to address these unmet needs in full, given the scale of the shortfall arising from the GBBCHMA, St Philips considers that South Warwickshire must play a significant role. It is important that South Warwickshire makes it clear that it will help address the acute unmet need and should, where possible, be specific in the exact proportion of the unmet need that the upcoming Local Plan can accommodate. Indeed, this is particularly pertinent, given the Inspector’s recent findings10 in respect of the Sevenoaks Local Plan where problems of unmet need were not adequately addressed through the duty to cooperate process, resulting in a terminal failure of legal compliance. Unless a proportionate contribution towards the unmet needs identified is accommodated, South Warwickshire risks not fulfilling its ‘duty to cooperate’ with neighbouring authorities, as required by paragraph 24 of the NPPF. St Philips supports South Warwickshire’s acknowledgement of the Duty to Cooperate but also recommends that a proportionate contribution should be made to ensure that the emerging Local Plan can pass the test of soundness. St Philips consider that a functional relationship approach is a suitable strategy and refers to Lichfields’ ‘The Black Country’s next top model’. Lichfields’ model drew on the precedent set in the C&WHMA/North Warwickshire and has been again supported by the emerging approach in the Leicester and Leicestershire HMA. Both Stafford Borough Council and South Staffordshire Council reflected on Lichfields’ model in the latest sustainability appraisals for the current consultations, St Philips therefore encourages South Warwickshire to adopt Lichfield’s model in order to sustainably distribute Birmingham’s and Coventry’s unmet housing need. The model calculates the proportion of housing that can be sustainably redistributed towards surrounding authorities based on the functional relationship between the administrative areas. Such a model takes account of the below trends within the HMA and between authorities with a functional relationship: 1 Migration patterns between authorities; 2 Commuting linkages between authorities; 3 Opportunities to capitalise on sustainable transport links; 4 Affordability pressures; and 5 The degree of environmental and physical constraints. The objective should be to create an agreed position with regard to the spatial distribution of housing that is justified based upon technical evidence and which can be used to underpin the preparation of Local Plans. This would ensure that as and when a spatial distribution methodology is agreed, South Warwickshire will have in place a sufficient supply of sites which have been tested through an acceptable model and other evidence base documents.
As set out above, St Philips considers that it is imperative that the SWLP assists with meeting the acute housing needs of neighbouring authorities. St Philips notes that the ‘SWLP Urban Capacity Study (October 2022)’ has established that South Warwickshire is unlikely to be able to meet its (or neighbouring authorities) development needs solely through the use of previously developed land.11 Therefore, regardless of whether the SWLP prioritises brownfield land, there will still be a need to identify suitable greenfield land for development. In this regard, sites such as Land at Jubilee Fields offer a sustainable location for housing growth. As discussed, St Philips considers that there is a need to disperse some growth to smaller settlements throughout the District. The Site is located on the edge of Stockton which offers a range of facilities and services such as a primary school, post office, restaurants, and a sports ground. It is located c.2 miles north-east of Southam and 8 miles south-west of Rugby. The village is connected to Leamington-Spa and Rugby by bus services 63 and 64. Small scale growth at Stockton would therefore benefit local services and support the overall sustainability of Stockton. The Site could therefore contribute to helping meet the needs of South Warwickshire and its neighbours.
3.48 WDC and SDC 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. 3.49 Taylor Wimpey consider that 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. 3.50 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 for. Indeed, the current approach has impacted timescales for plan making elsewhere in the GBBCHMA. Since Birmingham’s 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. 3.51 This also needs to be considered in the context of unmet needs from other HMA 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 WMCA 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. 3.52 At this stage we 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: • Reviewing 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. • Reviewing 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). 3.53 Whilst reviewing the 2018 Growth Study would be a useful part of any SoCG evidence base, we are of the view this must be a fresh study that goes beyond the scope of the previous report and, similarly to the CWHMA and LLHMA’s approaches, consider a model for distributing the unmet needs that goes beyond identifying growth areas. This must include detailed analysis and consideration of other models used by other HMA geographies for distributing unmet needs.
3.54 The overall contribution to any shortfall should be based on functional relationships, for example with WDC and Coventry, and between Stratford and Birmingham. Once this principle has been determined, growth should then be located in the most sustainable locations within WDC and SDC. 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.
No answer given
No answer given
St Philips welcomes South Warwickshire’s acknowledgement of the need to help meet the unmet needs of the Coventry and Warwickshire Housing Market Area [C&WHMA] and the GBBCHMA. The IO states: “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. However, South Warwickshire is also within the Birmingham and Black Country HMA… Through the duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs” (Page 111). 2.64 In this regard, St Philips notes that within the GBBCHMA there is emerging evidence of an acute level of unmet housing needs. Birmingham City Councils New Local Plan 2020-2042-Issues and Options [BCCIO] has recently confirmed that, as of March 2022, Birmingham’s LHN figure is 7,136 dpa (Para 4.7). This includes an additional 35% for the top 20 largest cities in the UK. 2.65 Cumulatively, this would equate to a housing need figure of 149,286 dwellings for the 22-year plan period (2022 to 2042). The BCCIO states that the Council can currently demonstrate a supply of 70,871 dwellings, which includes completions between 2020/21-2021/22 of 6,624 dwellings. The BCCIO concludes that, at present, there is a shortfall of around 78,415 dwellings to be found through the preparation of the BDP Review (Para 4.15). 2.66 Alongside Birmingham’s emerging unmet needs (c.78,000), another significant source of potential unmet needs is from within the Black Country. It is important to note that the Black Country Plan is no longer being jointly prepared and thus the Black Country Authorities will now prepare individual Local Plans; however, it is highly likely that the unmet need for housing c.28,000 dwellings still remains in the Black Country; albeit, now disaggregated amongst the four Black Country Authorities. As such, the level of unmet housing needs in the GBBCHMA is likely to be severe. 2.67 St Philips acknowledges that Coventry’s need has been reduced from 3,188 dpa as per the 2014-based projection to 1,964 dpa as per the trend-based projection. Although, it is important to note that an updated housing trajectory has not yet been released for Coventry meaning that the unmet need is yet to be calculated. It is highly likely that South Warwickshire will need to accommodate part of this unmet housing need. Given that Coventry has a very small amount of land that is outside of the urban area and free from constraints (equating to c.2% of the authority’s area) St Philips consider that it is extremely likely that Coventry will require further assistance in meeting its housing needs post-2031. 2.68 In this context, paragraph 11b of the NPPF is clear that: “b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: (i) the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or (ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole” 2.1 In this regard, the IO recognises that “given the size of South Warwickshire it is considered that any additional needs can be accommodated outside of any protected areas” (Page 109). The exception to this is noted to be areas within the Green Belt, however these sites would only be considered if suitable, appropriate, and necessary. St Philips considers that areas like South Warwickshire with such a large quantum of available land have a duty to support housing growth and not only address its housing need, but also the shortfall of housing provision within surrounding authority areas. 2.2 Whilst St Philips acknowledges that it is not for South Warwickshire to address these unmet needs in full, given the scale of the shortfall arising from the GBBCHMA, St Philips considers that South Warwickshire must play a significant role. It is important that South Warwickshire makes it clear that it will help address the acute unmet need and should, where possible, be specific in the exact proportion of the unmet need that the upcoming Local Plan can accommodate. 2.3 Indeed, this is particularly pertinent, given the Inspector’s recent findings10 in respect of the Sevenoaks Local Plan where problems of unmet need were not adequately addressed through the duty to cooperate process, resulting in a terminal failure of legal compliance. Unless a proportionate contribution towards the unmet needs identified is accommodated, South Warwickshire risks not fulfilling its ‘duty to cooperate’ with neighbouring authorities, as required by paragraph 24 of the NPPF. St Philips supports South Warwickshire’s acknowledgement of the Duty to Cooperate but also recommends that a proportionate contribution should be made to ensure that the emerging Local Plan can pass the test of soundness. 2.4 St Philips consider that a functional relationship approach is a suitable strategy and refers to Lichfields’ ‘The Black Country’s next top model’. Lichfields’ model drew on the precedent set in the C&WHMA/North Warwickshire and has been again supported by the emerging approach in the Leicester and Leicestershire HMA. Both Stafford Borough Council and South Staffordshire Council reflected on Lichfields’ model in the latest sustainability appraisals for the current consultations, St Philips therefore encourages South Warwickshire to adopt Lichfield’s model in order to sustainably distribute Birmingham’s and Coventry’s unmet housing need. 2.5 The model calculates the proportion of housing that can be sustainably redistributed towards surrounding authorities based on the functional relationship between the administrative areas. 2.6 Such a model takes account of the below trends within the HMA and between authorities with a functional relationship: 1 Migration patterns between authorities; 2 Commuting linkages between authorities; 3 Opportunities to capitalise on sustainable transport links; 4 Affordability pressures; and 5 The degree of environmental and physical constraints. 2.7 The objective should be to create an agreed position with regard to the spatial distribution of housing that is justified based upon technical evidence and which can be used to underpin the preparation of Local Plans. 2.8 This would ensure that as and when a spatial distribution methodology is agreed, South Warwickshire will have in place a sufficient supply of sites which have been tested through an acceptable model and other evidence base documents.
As set out above, St Philips considers that it is imperative that the SWLP assists with meeting the acute housing needs of South Warwickshire’s neighbouring authorities. Given the scale of the unmet need, St Philips considers that there is a need to review the Green Belt within the district. In this context, St Philips welcomes the IO’s recognition that: “A review of the Green Belt across South Warwickshire is an important piece of evidence to underpin the approach taken in the Local Plan. It would consider whether there are any areas which no longer meet all five of the Green Belt purposes and could be removed to allow for the most sustainable development to come forward, including the provision of affordable housing and employment opportunities.” (IO, page 57). 2.10 St Philips is highly supportive that the IOs approach has been ‘blind’ to whether a particular location or corridor is in the Green Belt. This approach ensures that sustainable locations within the Green Belt are not prematurely excluded from consideration. The IO recognises that: “The location and spread of the Green Belt in South Warwickshire may mean that limiting growth to locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option as it pushes development away from areas that are well connected with good infrastructure and better access to facilities and services towards areas with more limited infrastructure and where further travel would be necessitated” (page 56). 2.11 Notwithstanding the above, St Philips acknowledges that the NPPF is clear of the weight attached to the Green Belt by the Government, and that “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.” (Para 140). The NPPF sets out that prior to considering whether “exceptional circumstances” exist, local planning authorities should have “demonstrated that it has examined fully all other reasonable options for meeting its identified need for development” and goes onto provide a set of criteria that should be satisfied prior to establishing exceptional circumstances (e.g. a sequential approach of sorts) (Para 141). These include (inter alia) the optimisation of brownfield land, densities and discussions with neighbouring authorities. 2.12 In this regard, the Urban Capacity Study (October 2022) “has established that it is unlikely to be possible to meet currently development needs without significant greenfield development” (Urban Capacity Study, Page 1). There is also a significant, and persistent level of unmet housing need across the GBBCHMA and many of the Council’s neighbouring authorities are already unable to meet their own needs within existing urban areas. 2.13 In establishing the “exceptional circumstances” required to review the Green Belt, St Philips consider that the Council should also have regard to the acuteness of the unmet housing needs within the GBBCHMA, which might reasonably be considered an ‘exceptional circumstance’. Indeed, in the Calverton Parish Council v Nottingham City Council High Court Judgment11, the Judge pointed to the acuteness of the objectively assessed housing needs when considering whether housing need should be considered an exceptional circumstance (Para 51).12 2.14 As such, St Philips considers that the acuteness of the unmet housing need arising from the Birmingham HMA can, and in this instance, should, constitute exceptional circumstances, as established in the Calverton case. It is therefore entirely reasonable, and indeed necessary, for the Council to review the Green Belt within the District, to help meet the needs of South Warwickshire and its surrounding neighbouring authorities. Land at Brickyard Lane 2.15 As stated, St Philips is promoting Land at Brickyard Lane, Studley for residential development. As noted, the Site falls within the Green Belt. St Philips welcomes that the IO recognises that a review of the Green Belt is an important piece of evidence that should underpin the approach taken in the SWLP. 2.16 In this context, the NPPF is clear that the assessment of whether a site should be removed from the Green Belt is subject to a site's performance against the five purposes of the Green Belt (Para 143). The Coventry & Warwickshire Joint Green Belt Study – Stage 2 Final Report (April 2016) (“the Stage 2 Report”) considers the Green Belt land of six West Midlands councils including the area within the District. The purpose of the Stage 2 Report was to assess the identified Land Parcels against the five purposes of Green Belt as set out in the NPPF. The Site is located within the south-western corner of Parcel RE3, forming just under 3% of the 62ha of the large parcel. 2.17 The Stage 2 Report concluded that Parcel RE3 was a High-Performing parcel scoring 14 out of 20 across the five Purposes of the Green Belt Policy. However, whilst Parcel RE3 scored highly against Purpose 1, 2 and 3, the site does not possess the qualities of the larger parcel. This is because the parcel sizes used in the Stage 2 Report are overly large and it is considered the Site’s contribution to all the purposes would significantly reduce if the parcel was reduced in size or subdivided. However, owing to the fact that the Council has not yet undertaken a Gren Belt review, it is necessary to consider the Site’s performance against the five Green Belt purposes set out in the NPPF, independent of the broader parcel (RE2). As such, and to inform the Vision Document, St Philips has undertaken this analysis. The Vision Document demonstrates the Site’s performance: 2.18 Purpose 1: to check the unrestricted sprawl of large built-up areas – The site is located between Renshaw Industrial Estate to the west and residential dwellings of Studley to the east, with ribbon development already along the A448. The release of the land would not cause unrestricted sprawl towards Redditch or cause westward sprawl. The site would therefore not make a major contribution to Purpose 1; 2.19 Purpose 2: to prevent neighbouring towns merging into one another – The Green Belt would be approximately 0.2km deep between Redditch and Studley, and the release of the Site would not cause Studley to merge with Redditch; and 2.20 Purpose 3: to assist in safeguarding the countryside from encroachment – The neighbouring Renshaw Industrial Estate and residential housing provide urban influences on the site and provide clear and easily recognisable boundaries that would prevent encroachment of the countryside. As such, the new and proposed Green Belt boundary would not cause significant encroachment into the countryside. 2.21 In summary, the Site is a lower performing area of Green Belt land that does not significantly contribute to the purposes of the Green Belt. A new Green Belt boundary could be established that would follow existing physical features to provide a more resilient Green Belt boundary along Brickyard Lane and would rationalise the Green Belt on the west side of Studley. As such, St Philips consider that the release of the Site from the Green Belt would be suitable and would accord with the NPPF. 2.22 In addition to the above, St Philips note that the NPPF does not require only the release of sites which perform the worst against the Green Belt purposes (i.e. low Green Belt harm). There is a need to consider the broader Green Belt policies in the NPPF as a whole. As such, regard to should be had to the promotion of sustainable patterns of development, access to public transport, whether compensatory improvements could offset the harm from removal (Para 142), and consistency of the Green Belt with the emerging Local Plan strategy. It is, therefore, an essential part of the exceptional circumstances test that Green Belt land that fulfils poor to moderate Green Belt purposes can be released if it is consistent with the Local Plan strategy for meeting requirements for sustainable development, for example, to secure more sustainable patterns of development. 2.23 In this regard, the Site is located on the edge of Studley, a MRC which provides a range of services and facilities, including three supermarkets, a butchers, a chemist, primary and secondary schools and various community facilities. Studley is one of the largest villages in the District and is also identified as a suitable location for housing and business development and the provision of local services in the Core Strategy (Policy CS.15). It is also located c.5 miles south of Redditch with a regular bus service running through the village providing connections Redditch. The Site is situated between the existing urban edge of Studley and the Renshaw Industrial Estate with access to both Brickyard Lane and the A448. 2.24 As a part of the development proposals, new public open spaces are proposed in the northern and southern areas of the site, which will be multifunctional and accommodate areas for recreation, informal footpath routes, tree planting (new and existing), attenuation and ecological enhancement. 2.25 It is, therefore, a highly sustainable location for growth, with access to services and facilities and public transport. It is also well placed to meet Birmingham’s unmet needs in close proximity to where they arise. The delivery of environmental enhancements on-site, which would be achieved as part of the development, would ensure that any harm arising as a result of the removal of the Site from the Green Belt could be offset.
2.57. Birmingham City Council has identified a shortfall of 78,415 homes in its Local Plan Review 2042 Issues and Options Consultation Document, which equates to approximately 55% of the City’s total housing need (based on the latest HELAA). Under the current adopted Birmingham Local Plan the shortfall is 38,000 homes to 2031, which the Greater Birmingham and Black Country Strategic Housing Needs Study indicated would largely need to be met on greenfield sites, including green belt land outside Birmingham’s administrative area. Options, including urban extensions and growth around railway stations, were also identified as possible ways of addressing the shortfall.” (Black Country Plan Issues and Options, Paragraph 3.11). 2.58. The SWLP Consultation Document suggests that additional shortfalls could also arise from the Black Country authorities. The magnitude of the shortfall that the SWLP might need to accommodate up to 2050 therefore has the potential to be quite significant. On which basis it is imperative that the relevant Councils engage fully as a matter of urgency in the duty to co-operate process to establish what percentage of the identified shortfall the SWLP plan area will be responsible for.
2.59. The Respondent considers that if shortfalls from outside of South Warwickshire need to be meet then these would be best accommodated close to the source of those needs and/or locations that are proximate in terms of sustainable transport connections, and particularly rail services, which benefit from a reasonable commute. Such locations are likely to reside in the Green Belt. 2.60. For the reasons explained under Q-S5.2, the Respondent would caution the Councils against the development of a growth strategy that is overly reliant on the delivery of new settlements and should also look to maximise opportunities adjacent to existing settlements with sustainable transport connections and particularly rail.
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 approach taken to address the housing shortfall and we will continue engage in joint working through the GBBCHMA with South Warwickshire to address the GBBCHMA housing shortfall up to 2050. We welcome the approach of identifying reserve sites within Stratford-on-Avon and recommend that the Local Plan should continue to test a number of scenarios which could help to meet the GBBCHMA shortfall. It is noted that the consultation refers to the recent Birmingham Local Plan Issues and Options consultation (2022) which identifies a significant potential shortfall of 78,415 homes. It should also be noted that the recent work on the Black Country Plan (Regulation 18, Draft Plan in Summer 2021) although now ceased, identified a significant housing shortfall of 28,239 homes for the period 2020-2039. The scale of that potential shortfall should therefore also 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.
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. We consider the most sustainable locations are those that provide sustainable commuting links. Within the spatial options there is the potential for the delivery of new settlements. 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. Therefore, development in and around those locations that are or could be major sources of employment in South Warwickshire would also be appropriate as they could provide a balance of homes and jobs and reduce the need to travel.
No answer given
It is considered that if the region is required to meet housing shortfalls from outside of South Warwickshire, then it is appropriate to use brownfield sites and new settlement options are appropriate. These should include infrastructure to support new and existing communities.
Issue H4: Accommodating needs from elsewhere. Birmingham and Coventry cannot guarantee to accommodate all their own housing needs, although the planning reform proposals floated by Government have ‘muddied the waters’ in this respect. Strategic planning is the natural solution to this but sadly the Planning reform proposals are confusing on the scope for cross boundary working. Furthermore the West Midlands mayor has absolved any responsibility for sub-regional planning through the Combined Authority (although it has not stopped him commenting on planning and green belt matters!). The solution to this issue must therefore be resolved through the Duty to Co-operate (or the alignment policy – once the Government has decided what this means).
It is logical that any notional housing needs attributed to Birmingham and Coventry should be provided reasonably close to their boundaries. This would tend to suggest that sites would therefore need to be found either in the green belt and /or mainly in Warwick District. With respect to these residents, it would also be logical for there to be available public transport links to provide the ‘umbilical cord’ to fulfil work commitments and satisfy social relationships. The potential scale of this West Midlands overspill is huge. According to the Birmingham Issues and Options Plan there is currently a 78,415 shortfall plus a 28,000+ shortfall from the Black Country. The text also suggests that Coventry has a shortfall amounting to 1964 dwellings per annum. Clearly it would be preferable to engage in some form of strategic planning so that these pressures can be assessed in a comprehensive way.
In particular, we support the statement the following statement from the Issues and Options consultation document: . 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. This would be consistent with paragraph 11b of the National Planning Policy Framework (NAAONB) and with the Government’s ‘Natural Environment’ planning practice guidance23, particularly given the following factors: .The Cotswolds National Landscape occupies a small proportion of South Warwickshire (approximately 8%). . The Cotswolds National Landscape is the part of South Warwickshire that is furthest from Birmingham, the Black Country or Coventry. . A large proportion of the Cotswolds National Landscape within South Warwickshire consists of the Cotswold escarpment, escarpment outliers or high wold. The escarpment and high wold (including the views associated with them) are ‘special qualities’ of the Cotswolds National Landscape. The views associated with the escarpment outliers are a key feature / characteristic of that landscape character type. 23 https://www.gov.uk/guidance/natural-environment#landscape. Paragraph 041 Reference ID: 8-041-20190721.
In principle, the housing shortfall would best be accommodated by applying Growth Strategy Option 4 (Sustainable Travel and Economy), focussing on suitable areas that are relatively close to the urban areas where this shortfall arises and / or close to public transport options that provide good connectivity with these areas, having regard to (but not necessarily excluding) potential constraints such as Green Belt.
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.
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? No 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. Q- H4-2 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.
Q-H4-1: Chapter 6 of the South Warwickshire Local Plan Part 1 (Stage 2: Issues and Options Consultation, January 2023), states that ‘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. However, South Warwickshire is also within the Birmingham and Black Country HMA owing to Stratford-on-Avon District’s shared boundaries and inter-relationships with Solihull and Redditch boroughs and Bromsgrove district’. The identified sites in Stratford-on-Avon amount to a total of 530 dwellings, including STR.D – East of Banbury Road, Stratford-upon-Avon which has infrastructure constraints. In accordance with the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Position Statement Addendum (December 2021), the total shortfall of housing is 66,139, comprising of 37,900 arising from Birmingham and 28,239 from the Black Country. In 2021, the identified contribution from Authorities within the housing market area totalled 13,935. Thus, there remains a significant shortfall across the HMA which has not been accounted for. Given the scale of the unmet need, we strongly disagree with the Council’s proposed approach to meeting the Birmingham and Black Country shortfall. It is not clear what evidence the Council is using to underpin this approach. Thus, if South Warwickshire were to continue without further evidence, the test of soundness would not be satisfied. Moreover, South Warwickshire should be fostering a positive and proactive approach to delivering sustainable housing to assist in addressing the current housing crisis. The NPPF (2021), is clear that for a Plan to be found sound. it must be positively prepared which includes as a minimum ensuring that ‘unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development’. We are not aware of any evidence which demonstrates that allocating additional sites to contribute to meeting the Birmingham and Black Country HMA shortfall to 2031 is unpractical or fails to achieve sustainable development. Thus, we strongly recommend that South Warwickshire include an uplift on their housing need to address this identified unmet need. We do however agree that given the location of the unmet need, the allocation of additional sites would be most appropriate within Stratford-on-Avon given its proximity to the source of the unmet need. Q-H4-2: As detailed above in our response to Q-H4-1, South Warwickshire should be allocating additional sites to assist in meeting the Birmingham and Black Country HMA shortfall to 2031. The South Warwickshire Local Plan subject of this consultation does however have a plan period of up to 2050. Thus, in order for the plan to meet the test of soundness, it must take into account the shortfall arising over that period. Birmingham City Council has commenced its Local Plan Review to 2042. The Council has identified a shortfall in housing of 78,415 homes. The Black Country Local Plan is no longer proceeding and the Local Plans for the four Black Country Councils will now be prepared separately. Thus, it may be that an additional shortfall for the HMA will be identified through the planmaking process. Therefore, South Warwickshire should accommodate a proportion of the shortfall identified by Birmingham up to 2050. It is also highly likely additional unmet need will arise from the Black Country and we recommend that South Warwickshire keep this under constant review to ensure a flexible Plan is prepared which can assist in meeting any unmet need identified. It is essential that this is incorporated within the plan to ensure that it meets the test of soundness by being positively prepared, justified, effective and consistent with national planning policies.
It is our view that the ideal position would be to allocate sites for unmet need as close to the area which has an identified unmet need. However, given the scale of the unmet need to be accommodated within South Warwickshire, this approach could lead to disproportionate growth in certain areas which could have a determinantal impact on achieving sustainability. Thus, we recommend that approach is undertaken in conjunction with utilising the Council’s settlement hierarchy to direct development towards the most sustainable settlements in South Warwickshire.
No answer given
See above comments at Q-S10. Green Belt should be the last option not the first.
No answer given
No answer given
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? Yes. South Warwickshire is inextricably linked with three wider housing market areas; Birmingham, Coventry and the Black Country. For Birmingham, the latest evidenced position is that unmet need is in excess of 78,000 houses. This is a materially worsening position, and it is likely that the actual unmet need will be substantially greater at the point of SWLP examination and adoption. Coventry has a significant housing requirement, which it too cannot meet in full. The precise unmet need is being determined, once known this too will need to be factored in. The Black Country is a third HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline. Q-H4-2 Please add any comments The Black Country is a HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline.
The extent of the shortfall from the wider HMA’s is so significant that by ring fencing its delivery there risks a plan strategy which is driving by HMA issues rather than being developed in the context of sustainable development. Thus, whilst the temptation will be to accommodate housing to serve the wider HMA’s at the northern edge of the SWLP plan area, we consider that the approach should be to a) identify the overall housing requirement for the SWLP having regard to ‘internal’ housing requirements and HMA unmet need; and then b) develop a plan strategy to deliver all of this housing in full. This avoids any form of ring fencing within the SWLP area. It also avoids the complex trigger mechanisms set out in the draft SAP which are, in practice, difficult to apply in a development management context.
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? Yes. South Warwickshire is inextricably linked with three wider housing market areas; Birmingham, Coventry and the Black Country. For Birmingham, the latest evidenced position is that unmet need is in excess of 78,000 houses. This is a materially worsening position, and it is likely that the actual unmet need will be substantially greater at the point of SWLP examination and adoption. Coventry has a significant housing requirement, which it too cannot meet in full. The precise unmet need is being determined, once known this too will need to be factored in. The Black Country is a third HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline. Q-H4-2 Please add any comments The Black Country is a HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline.
The extent of the shortfall from the wider HMA’s is so significant that by ring fencing its delivery there risks a plan strategy which is driving by HMA issues rather than being developed in the context of sustainable development. Thus, whilst the temptation will be to accommodate housing to serve the wider HMA’s at the northern edge of the SWLP plan area, we consider that the approach should be to a) identify the overall housing requirement for the SWLP having regard to ‘internal’ housing requirements and HMA unmet need; and then b) develop a plan strategy to deliver all of this housing in full. This avoids any form of ring fencing within the SWLP area. It also avoids the complex trigger mechanisms set out in the draft SAP which are, in practice, difficult to apply in a development management context.
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? The shortfall being planned for through the emerging Stratford on Avon Site Allocations document to meet a previously-identified unmet need arising from the Birmingham and Black Country HMA is separate (in terms of scope, area and documentation) to the considerations underway for the South Warwickshire Local Plan. This current consultation should focus on what the appropriate strategy should be for the combined area, in the context of the wider relationships with different HMAs for the Plan period up to 2050, and should be based on the latest housing data. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan The housing need within the Greater Birmingham and Black Country HMA is still under review, following the halting of the joint Black Country Local Plan. The Black Country authorities are currently reconsidering their housing needs and how this will impact on the wider HMA. In light of this, the significant housing shortfall identified by Birmingham City Council, and the likelihood that Coventry City Council will not be able to accommodate all of its housing needs (even at the reduced trend-based level of 1,964 homes per annum), the South Warwickshire authorities will need to consider how additional unmet need from these areas could be accommodated within the Local Plan area. It is noted that page 109 of the Issues and Options consultation document highlights that there is a strong argument that if homes are being provided to meet needs arising in Coventry and Birmingham then those homes should be located as close as possible to the source of those needs in order to minimise travel. Crest Nicholson contends that areas should be being considered from the start of the Local Plan review process which are / could be able to accommodate unmet need. This includes established residential locations on the edge of Coventry City. There is a need for the South Warwickshire Councils to continue to monitor the housing capacity studies being undertaken in the Birmingham and Black Country HMA and by Coventry City Council to assist with identifying what appropriate contributions it might need to make to assist with meeting the unmet need.
The links with Coventry City arise through commuting patterns, as well as the physical location of Warwick District on the edge of the Coventry built up area. The relationship with the Birmingham and Black Country HMA is intrinsically linked to the migration / commuting patterns. Good connectivity with the primary transport infrastructure in both instances is important, notably in relation to the sustainable travel infrastructure to provide access to the relevant, employment, leisure and community facilities, both within this external HMA and within the South Warwickshire Local Plan area. Sites for housing development should be located where this can be achieved. As identified in response to Issue 6 (Green Belt) and in response to the identified spatial growth options, a spatial distribution strategy which capitalises on opportunities provided by the existing sustainable transport network, as well as providing good connectivity between homes and employment opportunities in main towns is important. Locations that can achieve this through existing sustainability credentials, or can be made more sustainable through additional development, should be considered for allocation. This should include appropriately located land in the Green Belt or land that has already been removed from the Green Belt in order to meet development needs. In the case of meeting some of the housing need for Coventry, and in the context of locating development in close proximity to sustainable travel routes to Birmingham, the expansion of the committed Crest Nicholson housing site to the south of Westwood Heath Road can make an important contribution. This site is considered to be capable of providing c.50-150 additional homes over and above the current allocation for 425 units, which is currently being built out. Further details are set out in the Vision Document accompanying these representations.
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? No Bellway consider that a review of sites available should be undertaken. Sites allocated within the Site Allocations Plan (which is not yet adopted) should be considered separately to the SWLP and any proposed retention of existing allocations with no planning permission should be reviewed and confirmed if they are still deliverable. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan Bellway consider that the SWLP should be accommodating growth to meet the housing shortfall arising from the Greater Birmingham and Black Country HMA. There is an identified shortfall of circa 28,000 dwellings across the Black Country up to 2039 and circa 78,000 dwellings from Birmingham up to 2042 which is considered to be significant. The NPPF (paragraph 35) requires plans to accommodate unmet need from neighbouring areas where it is practical to do so. Given the close proximity of the SWLP area to the Greater Birmingham HMA, Bellway consider that in order to be found sound, the SWLP should include a contribution towards the significant shortfall.
Bellway considers that specific sites should be allocated to meet the needs of the HMA. However, as said elsewhere in their response, Bellway considers that the SWLP should identify housing growth adjacent to existing settlements outside of the Green Belt, such as Long Itchington, in the first instance
We support the recognition that the SWLP will have a role to play in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that the Issues and Options Birmingham Local Plan identifies a housing shortfall of 78,415 dwellings. However, no reference is made to the extent of the housing shortfall arising from the Black Country. Following the abandonment of the Black Country Plan, the four Black Country authorities are producing individual Local Plans. However, as the Preferred Options version of the Black Country Plan included a housing requirement shortfall figure based upon the Standard Method, the identified housing shortfall in the Preferred Options version of the plan can be considered a credible starting point for the consideration of the potential housing shortfall. The Preferred Options Black Country Plan identifies a housing shortfall of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbation is 106,653 dwellings. We note that the Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes to support the growth requirements of the Birmingham and Black Country conurbation. This is the equivalent to less than 5% to 10% of the total housing shortfall. It is entirely possible that a greater level of housing growth will be required in the SWLP plan area. In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing requirement for Coventry should be significantly below the Standard Method housing requirement for the city this has yet to be tested. It is a realistic proposition that it may be established that Coventry should seek to deliver a Standard Method compliant housing figure. The SWLP, therefore, consider options for delivering additional housing to support for the growth of Coventry.
No answer given
Issue H4: Accommodating housing needs arising from outside of South Warwickshire 4.20 Catesby Estates supports both Councils in recognising that they have a responsibility to contribute towards meeting unmet housing needs arising from within both Birmingham and Coventry. Catesby Estates also supports the recognition that, even if the trend-based alternative approach to housing need is pursued, Coventry may not be able to accommodate all of its revised housing need (1,964 homes per annum.) Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.21 In addition to the existing shortfalls identified for the period to 2031, Birmingham City Council has also commenced work on its Local Plan Review to 2042 and has recently published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes to 2042. Additional shortfalls may also be identified arising from the Black Country authorities, notwithstanding the cessation of the Black Country Core Strategy. 4.22 The Consultation Document identifies that, for the purposes of the accompanying Sustainability Appraisal, Stratford and Warwick District Councils have tested the effects of an additional 5,000 and 10,000 homes. 4.23 Catesby Estates broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 4.24 Furthermore, it is important to note that this unmet need covers the period to 2042, whereas the South Warwickshire Local Plan is proposed to run to 2050. Any contribution towards this need made within the South Warwickshire Local Plan should accordingly be capable of being delivered within the required timeframe, and not left until the end of the South Warwickshire Local Plan period.
4.25 As acknowledged within the Consultation Document, there is a strong argument that, if homes are being provided to meet needs arising in Coventry and Birmingham, then those homes should be located as close as possible to the source of those needs in order to minimise travel. 4.26 As such, sites along the railway corridors and near the M40 are likely t o help accommodate unmet need from Birmingham and the Black Country, whilst sites south of Coventry can be identified and serve the wider housing shortfall of Coventry. 4.27 However, these is a credible argument that the focus should be on delivering growth across the Districts in line with the chosen spatial strategy which achieves the desired objectives including proximity to public transport and services and addressing affordability; rather than solely its proximity to the source of the unmet need. 4.28 Lastly, linked with our responses to Questions S3-1 and H1-1, the meeting of additional unmet need from neighbouring authorities is likely to necessitate the development of greenfield land.
No answer given
You say “Certainly, there is a strong argument that if homes are being provided to meet needs arising in Coventry and Birmingham, then those homes should be located as close as possible to the source of those needs in order to minimise travel.” We are very concerned that Long Itchington is one of the closest northerly places outside of the West Midlands Green Belt and we could envisage that it is proposed to put the over-spill housing need from Birmingham and Coventry within our parish and/or Southam. This is particularly concerning as both Long Itchington and Southam are situated with good road links to Coventry and Birmingham. We urge you not to do this. Southam has experienced the second largest growth in a town (second only to Stratford itself) and Long Itchington has taken the largest proportion of housing of any LSV1.
We support the recognition that the SWLP will have a role to play in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that the Issues and Options Birmingham Local Plan identifies a housing shortfall of 78,415 dwellings. However, no reference is made to the extent of the housing shortfall arising from the Black Country. Following the abandonment of the Black Country Plan, the four Black Country authorities are producing individual Local Plans. However, as the Preferred Options version of the Black Country Plan included a housing requirement shortfall figure based upon the Standard Method, the identified housing shortfall in the Preferred Options version of the plan can be considered a credible starting point for the consideration of the potential housing shortfall. The Preferred Options Black Country Plan identifies a housing shortfall of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbation is 106,653 dwellings. We note that the Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes to support the growth requirements of the Birmingham and Black Country conurbation. This is the equivalent to less than 5% to 10% of the total housing shortfall. It is entirely possible that a greater level of housing growth will be required in the SWLP plan area.
In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing requirement for Coventry should be significantly below the Standard Method housing requirement for the city this has yet to be tested. It is a realistic proposition that it may be established that Coventry should seek to deliver a Standard Method compliant housing figure. The SWLP, therefore, consider options for delivering additional housing to support for the growth of Coventry.