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?
We consider that in order for the SWLP to be positively prepared and legally compliant it must consider accommodating unmet need arising outside of South Warwickshire. We acknowledge that national planning policy and the law has the potential to change during the course of the SWLP’s preparation and for the Duty to Cooperate to be replaced with an “alignment policy.” However, there is no suggestion that the need for local authorities to address unmet needs should be removed generally and we would encourage the councils to continue dialogue and cooperation with their neighbours to address sub-regional issues including unmet hosuingneed arising from surrounding urban areas. Birmingham City Council has published a Local Plan Issues and Options Consultation document in October 2022, which identifies a shortfall of some 78,415 dwellings to 2042. Many of Birmingham’s neighbouring authorities such as the Black Country authorities are constrained by the Green Belt, extensive urban areas and have unmet needs of their own. It is clear that many of the areas with the closest functional relationship to Birmingham, including those within South Warwickshire, are also constrained by the Green Belt and we consider a robust Green Belt review in those areas to be key to accommodating unmet housing need across the wider sub-region. It is also unlikely that Coventry will be able to its housing need as identified in the Warwcikshirewide HEDNA noting that the adopted Coventry Local Plan identified a shortfall of some 22,000 dwellings to be met elsewhere. We would anticipate similar shortfalls arising over the period to 2050 and given the close functional relationship between South Warwickshire and Coventry we would expect a good proportion of the unmet need to be directed accordingly.
As to the location for accommodating the shortfalls from other areas we would note that the parts of the plan area closest to Coventry and Birmingham are within the Green Belt and also contain many of South Warwickshire’s most sustainable settlements. As such, a Green Belt review is fundamental to accommodating any identified shortfalls in a sustainable manner to the extent they reasonably can be.
2.53. Yes broadly. The Respondent agrees that there is a strong argument that the homes needed to contribute to the Birmingham and Black Country HMA shortfall to 2031 should be located close to the source of those needs. However, the Respondent considers that locations that are proximate in terms of sustainable transport connections, and particularly rail services, which benefit from a reasonable commute to sources of need should also not be ruled out. Q-H4-2: Do you have any comments about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan? Y/N/DK 2.54. Birmingham City Council has identified a shortfall in housing 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). 2.55. The SWLP Consultation Document suggests that additional shortfalls could also arise from the other 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.
2.56. 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. 2.57. 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.
Q-H4.1: No, we do not agree because the shortfall needs to relate to the whole Plan period up to 2050 and there should be no cut-off at 2031. In addition, there needs to be the shortfall needs for Coventry and to an extent Solihull. Q-H4.2: This is an appropriate time to re-assess the actual boundaries of the HMA that are applicable to South Warwickshire because there will be some “in-commuting” from other surrounding Districts which need to be taken into account. This is often the most heavily fought part of the Local Plan Inquiry and once again there needs to be a robust External Consultant report advising the South Warwickshire authority on the needs and requirements for the whole of the Plan period up to 2050.
No answer given
The LPAs need to focus on lessons learnt. Previous erroneous estimates of the population growth in Coventry has led to allocation of greenfield land in South Warwickshire for housing to meet a need that never existed. Duty to Cooperate does not mean duty to agree - South Warwickshire must be robust in challenging demands of large local authorities.
The suggestion that houses should be built in the Green Belt is absolutely wrong. This would undermine the purpose of the Green Belt to prevent urban sprawl. The essential characteristics of permanence and openness of the Green Belt must be protected.
Q-H4.1: No, we do not agree because the shortfall needs to relate to the whole Plan period up to 2050 and there should be no cut-off at 2031. In addition, there need to be the shortfall needs for Coventry and to an extent Solihull. Q-H4.2: This is an appropriate time to re-assess the actual boundaries of the HMA that are applicable to South Warwickshire because there will be some “in-commuting” from other surrounding Districts which need to be taken into account. This is often the most heavily fought part of the Local Plan Inquiry and once again there needs to be a robust External Consultant report advising the South Warwickshire authority on the needs and requirements for the whole of the Plan period up to 2050.
No answer given
Warwick District and Stratford-on-Avon District 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. IM Land 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. 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. 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. 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). 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.
The overall contribution to any shortfall should be based on functional relationships, for example with Warwick District and Coventry, and between Stratford and Birmingham. Once this principle has been determined, growth should then be located in the most sustainable locations within Warwick District and Stratford-on-Avon District. 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.
2.25 The significant level of unmet need within the region and HMA are now well established. The NPPF is clear about the scenarios wherein it is possible to deny a legitimate request from a neighbouring authority for support to meet unmet needs. These are where; 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 (footnote7 of the NPPF); 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. 2.26 Whilst the Plan area includes areas protected by footnote 7, it is not so prevalent as to justify a failure to meet a quantum of unmet need from the HMA. Moreover, in accordance with the PPG, the Plan should establish its fair quantum of unmet need as part of the housing requirement process, independently from, and prior to establishing the ability of the area to meet that need. It is not compliant with the PPG to establish a notional capacity for development, then simply offer that as a contribution to unmet needs. Conversations need to be held at a strategic level, establishing the quantum of unmet needs in full, and this distribution of this need being agreed through Statements of Common Ground. This should then be reflected in the adopted housing requirement. 2.27 The Plan should also be clear as to what quantum of what unmet need it is meeting. It is not suitable to simply supply a number as a contribution to meeting the needs of all, each contribution needs to be individually and specifically quantified, as this will directly inform future conversations and Local Plan examinations. For clarity, this means the Plan should be clear how much unmet need it is proposing to meet as part of its housing requirement for Coventry, Birmingham and the Black Country.
2.28 The most appropriate way to meet unmet housing is to add it to the overall housing requirement (in accordance with the PPG and NPPF) and distribute that housing requirement through the spatial hierarchy in accordance with the adopted special strategy. It is not considered appropriate to try and deliver specific sites, particularly strategic, with the sole aim of meeting unmet needs, as clearly there are no controls that can be placed on ensure the development is actually utilised in that manner. Given it is impossible to control the actions of individuals and where they will wish to live, there is no policy justification for this approach. Distribution through the spatial strategy will ensure the Plan in internally consistent and logical, and also will provide choice and competition in the market for housing, which will serve the range of people whose needs may be unmet in their current or desired location.
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? Policy SAP.4 of the Stratford-on-Avon Site Allocation Plan Revised Preferred Options (June 2022) intends to provide Stratford’s contribution to meeting Greater Birmingham & Black Country’s shortfall to 2031 on the following sites: - STR.A – North of Evesham Road, Stratford-upon-Avon - STR.B – East of Shipston Road, Stratford-upon-Avon - STR.C – South of Alcester Road, Stratford-upon-Avon - MAPP.A – West of Birmingham Road, Mappleborough Green We do not object in principle to the majority of the unmet need being provided in Stratford, however the three sites proposed in Stratford are less suitable locations for growth than to the northeast of Stratford for the reasons set out in our answer to question Q-S4.2. It is identified that an additional shortfall of some 78,000 homes for the Greater Birmingham and Black Country HMA will be required up to 2042. Whilst the review of Birmingham City Council’s Local Plan to 2042 is ongoing, we encourage the Council to be proactive and look to plan for accommodating part of this unmet need within South Warwickshire, which is likely to be greater than 78,000 homes should the plan period match the SWLP to 2050. 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 scale of any shortfall to meet the housing needs of the Birmingham and Black Country HMA should be proportionate and reasonable for South Warwickshire. Whilst the current draft of the Levelling Up and Regeneration Bill looks to remove the Duty to Co-operate, this has not yet gained Royal Assent and the transitional arrangements within the NPPF mean that the current NPPF plan-making rules will apply to this emerging Local Plan and therefore paragraph 35(a) will still apply which required unmet need to be accommodated where it is practical to do so and is consistent with achieving sustainable development. The collapse of the Birmingham Development Plan has created uncertainty about how much housing will need to be exported to areas including South Warwickshire. It is likely that the figure will increase the SWLP will need to contribute towards meeting this need.
If the Council are required to meet housing shortfalls from outside of South Warwickshire it should be accommodated in the most sustainable locations for growth even if this means releasing further Green Belt land to achieve sustainable patterns of growth.
38. 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. 39. 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 40. There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. 41. 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. 42. 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. 43. 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. 44. 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. 45. 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 46. 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. 47. 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. 48. 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. 49. 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/]
50. 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.
Unmet housing needs from the wider housing market area. Stratford-upon-Avon Council (as part of the South Warwickshire Plan area) have been a proactive participant in HMA discussions in seeking to provide additional housing to meet any shortfalls within Birmingham and the wider the HMA area. This is reflected and welcomed in the emerging Stratford-on-Avon Site Allocations Plan (Policy SAP.4) which makes a number of Reserve Site allocations with a total capacity of approximately 380 homes to meet the needs of the Greater Birmingham and Black Country HMA up to 2031. Birmingham City Council fully supports this approach and the continued need for unmet needs from elsewhere within the HMA is evident in shortfalls demonstrated within the Black Country and latest household requirement figures for Birmingham in the Issues and Options consultation for our new Local Plan. Although the new Local Plan is still in the early stages of its production, the City Council has commissioned a Housing and Employment Development Needs Assessment (HEDNA) as well as a Housing and Employment Land Availability Assessment (HELAA) as part of its evidence base. These two studies, coupled with wider urban capacity work, has shown that there is an initial estimated shortfall of 78,415 homes across the City for the proposed Plan period of 2022-2042. The City Council still has further work to do to identify further potential sources of housing land supply and will ensure that opportunities within its administrative area will be truly maximised prior to any shortfall being exported to other areas. However, it is highly likely that shortfalls will still remain as well as additional shortfalls from the Black Country authorities which are likely to be identified in the conurbation beyond 2031. We are therefore in full support of the summary position on Page 112 of your Issues and Options document which states that close working will need to continue across the Greater Birmingham and Black Country HMA to try and address any shortfall, including consideration of the strength of the relationship between the South Warwickshire authorities and the source of these shortfalls. We also very much welcome the testing of the effects of an additional 5,000 to 10,000 homes in the sustainability work for the South Warwickshire plan as a potential contribution to continued shortfalls elsewhere within the HMA. This position is therefore set out in detailed sustainability work in Chapter 4 of the Issues and Options Document which includes the potential for a new settlement or settlements within South Warwickshire as one of several options being considered to deliver the growth required over the plan period.
The City Council is supportive of the consideration of new settlements in the Plan which have the potential to serve the wider needs of the HMA and alleviate some of the pressures on the West Midlands Conurbation. A new settlement, which is well connected to the Conurbation by a wide choice of transport modes, may be a more sustainable option than urban extensions so it is essential that such options in areas such as South Warwickshire are explored which could mutually benefit the future sustainable growth of the HMA. The City Council would therefore support a potential location of a new settlement which is well connected to the West Midlands Conurbation to complement and provide the mutual growth benefits for South Warwickshire and the wider Greater Birmingham and Black Country HMA. Birmingham City Council will therefore continue to support on-going collaborative working across the HMA including further HMA-wide studies and Statements of Common Ground as a roadmap for further work and potential local plan allocations.
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.
Issue H4: Accommodating housing needs arising from outside of South Warwickshire 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 driven 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.
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. 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. 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. 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. 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.
Housing needs that cannot be met within neighbouring areas must be met as close as possible to those areas, or within areas where sustainable transport connections can easily be made to those areas. 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. Kenilworth is situated approximately 6 miles (10 km) to the south-west of Coventry and comprises the closest town within the District to the city. Kenilworth also benefits from a train station and excellent road connectivity to Coventry. As such, the market town is ideally located to accommodate any housing shortfalls from outside of South Warwickshire, particularly Coventry. In accordance with the guidance contained within the Framework, development should also 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. 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 Strategic Policy DS4 of the adopted Warwick District Local Plan. Kenilworth is identified as one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Warwick District. It offers a large range of services and facilities, including supermarkets, banks and hardware shops. The promotion site would be well connected to the built-up area of Kenilworth and would constitute sustainable development. Indeed, it is considered that the new homes at land at Warwick Road, Kenilworth will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Kenilworth’s services and facilities. Given the pressing need for additional housing within Warwick District, in addition to meeting the housing shortfalls from outside of South Warwickshire, Kenilworth is clearly a sustainable location to accommodate additional housing growth. The Site at land at Warwick Road, Kenilworth 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.
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.
Q-H4-3 If we are required to meet housing shortfalls from outside of South Warwickshire, how best and where should we accommodate such shortfalls? 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 driven by HMA issues rather than being developed in the context of sustainable development. Delivering growth to meet the wider HMA housing issues in the northern section of the SWLP area – such as at Hockley Heath – would ensure that wider HMA needs are met as closely as possible to the geographical area where the need arises. This is an inherently sustainable approach and should be the starting point for the SWLP.
The area shouldn’t choose to take more extra additional growth, this would put additional serious pressure on important habitats and environments in the area. The other Councils need to legitimately look to find land/ increase housing densities in their local areas.
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42. 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. 43. 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. 44. 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 inter-relationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 45. 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. 46. 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.
47. Contributions to meeting the Birmingham and Black Country HMA shortfall to 2031 can be accommodated by increasing the growth proposed for Option 5: Dispersed. Housing targets should be minimum ones in light of the wider Housing Market Area issue and the need to address the Birmingham and Black Country HMA unmet housing needs.
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45. Contributions to meeting the Birmingham and Black Country HMA shortfall to 2031 can be accommodated by either increasing the growth proposed for Option 5: Dispersed. Housing targets should be minimum ones in light of the wider Housing Market Area issue and the need to address the Birmingham and Black Country HMA unmet housing needs
4.1. Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of “significantly boosting” the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. 4.2. The Planning Practice Guidance (PPG) (paragraph 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. 4.3. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Housing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the Joint Plan area. 4.4. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle. The trend based figures, which equate to an overall housing need across the Joint Plan area of 1,679 dwellings per annum is supported in principle. 4.5. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. 4.6. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now, and will continue to exist in the future. 4.7. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix 2) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear.” 4.8. It is important to stress that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted Birmingham Development Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed into the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further.
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4.1. Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of “significantly boosting” the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. 4.2. The Planning Practice Guidance (PPG) (paragraph 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. 4.3. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Hosing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the Joint Plan area. 4.4. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle. The trend based figures, which equate to an overall housing need across the Joint Plan area of 1,679 dwellings per annum is supported in principle. 4.5. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. 4.6. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now, and will continue to exist in the future. 4.7. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix 2) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear.” 4.8. It is important to stress that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted Birmingham Development Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed into the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further.
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Claverdon recognise that SWLP has a duty to collaborate with the neighbouring authorities. The demand and need which comes from Birmingham and the Black Country is mainly for affordable homes. The problem of providing affordable homes in high land and house price areas has proved intractable nationally so that affordable and social housing numbers have declined sharply. When the SWLP announces proposed targets it must indicate the level of subsidy Homes England will allocate to areas such as Claverdon.
The scale of homes which Claverdon can absorb is dependent on affordability problems being addressed. However, the scale is also dependent on adequate modern infrastructure being provided. Without a significant change to the approach to funding infrastructure none of the options will be adequate.
The emerging plan will have to play a role in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that Birmingham’s Issues and Options document identifies a housing shortfall of 78,415 dwellings. 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, the Preferred Options version of the abandoned draft Black Country Local Plan included a housing requirement shortfall figure that can be considered a credible starting point for considering the potential housing shortfall for the Black Country; a figure of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbations is 106,653 dwellings. The Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes could be provided within South Warwickshire to support the growth requirements of the Birmingham and Black Country conurbation. This is equivalent to under 5% to 10% of the total housing shortfall. It is entirely possible that the SWLP will be required to deliver numbers near the top end of this range. In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing need for Coventry should be significantly below the Standard Method housing requirement for the city, this has yet to be tested. The Draft Plan should, therefore, consider options for delivering additional housing to support for the growth of Coventry.
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In line with other policy noted earlier in the Local Plan.
2.17.1 The approach to meeting needs to 2031 is supported. The scale and shortfall of future needs arising from Birmingham (78,415 to 2041) and the Black Country to 2050 is likely to be significant and will clearly need co-operation across authorities within the housing market area (and possibly further afield), including agreement on the scale of need and the basis for apportioning this to local authorities.
2.17.3 This question seems oddly framed since there is no provision currently in place to ‘require’ the authorities to meet shortfalls from outside of South Warwickshire. 2.17.4 As noted above, the I&O document recognises the need to consider un-met needs from neighbouring authorities. The timetable for the Joint Local Plan indicates that the Plan would be submitted by June 2025 and adopted by December 2025. It is therefore likely that the Local Plan will be examined under existing legal requirements (including the duty to co-operate). This highlights the need to ensure that any contribution to un-met needs arising from outside the district that the Councils agree to is incorporated in future iterations of the Local Plan. As the duty to cooperate relates to the preparation of the plan it cannot be rectified post-submission, so if the Inspector finds that the duty has not been complied with, they will recommend that the local plan is not adopted and the examination will not proceed any further (Planning Practice Guidance Paragraph: 031 Reference ID: 61-031-20190315). 2.17.5 The duty to co-operate therefore provides the mechanism for agreeing any arrangements but such arrangements would need to be agreed by the authors of the plan and relevant parties prior to the SWLP being submitted. An inspector could not amend the plan once it is submitted because any issues relating to the duty to co-operate cannot be rectified post submission. In terms of meeting any identified need it is suggested that the SWLP identifies specific sites that are suitably located to help meet needs arising from outside the district – with other sites allocated to meet needs arising from within the districts. The Green Belt represents a significant constraint. Options for accommodating sustainable development outside of the Green Belt should be considered before locations within the Green Belt are considered, consistent with Paragraph 141 of the NPPF.
Q-H4.1: We recognise that SWLP has a duty to collaborate with the neighbouring authorities. The demand and need which comes from Birmingham and the Black Country is mainly for affordable homes. The problem of providing affordable homes in high land and house price areas has proved intractable nationally so that affordable and social housing numbers have declined sharply. In Henley and the surrounding villages is by discounted land or public subsidy. When the SWLP announces proposed targets it must indicate the level of subsidy Homes England will allocate to areas such as the JPC . No housing target should be ratified without a fully funded strategy for affordable homes in high price settlements. If this is not possible the housing target for Henley/Beaudesert should be reduced accordingly. Q-H4.2: The scale of homes which the JPC area can absorb is dependent on affordability problems being addressed. However the scale is also dependent on adequate modern infrastructure being provided. Without a significant change to the approach to funding infrastructure none of the options will be adequate. The JPC has received views from 2-300 residents in the short time available. The community have made it clear that the infrastructure of Henley Beaudesert is seriously inadequate. There is anger about the quality of the road, rail and bus situation which have been wrongly identified as strengths of the town. There are several other serious concerns relating particularly to antiquated drainage and sewage systems and flood hazards. Unless the chosen option presents concrete proposals to deal with these issues in the early years of the plan none of the growth options will be acceptable.(Repetition of response I.4.3)
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Coventry City Council has just begun a Local Plan review. We are undertaking a housing capacity study and will work on a continual basis with our partners in South Warwickshire as part of the wellestablished culture of joint working and as part of the Duty to Co-Operate requirements. We welcome the inclusion of this subject in the SWLP and look forward to on-going joint working.
Issue H4; Sub Regional Housing Provision. In principle, the Chamber supports a regional approach to the provision of both housing and employment provision. Thus it follows that where south Warwickshire may agree or is required to take additional housing and employment provision from surrounding areas it should do so.
Ref. Q –H4-1-3. It is, of course, a matter of regret that no formal sub regional mechanism exists as part of the formal land use planning process . However, the Chamber fully supports the continuation of the strong cooperation, joint working and liaison across the region and sub region that has characterised the period since 2011.It is essential that this continues across the next plan period .It is regrettable that the development plans across Coventry and Warwickshire are not moving in step in a coordinated manner. However there is an opportunity for this joint plan “to set the agenda” for the subsequent local plan reviews across the Sub –region.
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The duty to coooperate was removed by the Secretary of State on 5 Dec 2022, as well as the standard method, the 5 year land supply, and the 35% uplift for the 20 largest towns and cities. This plan should only accept provision for other authorities on a voluntary case by case basis, at the plan review stages, after at least 5 or 10 years when we will have accurate information about real population growth and housing need.
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The duty to coooperate was removed by the Secretary of State on 5 Dec 2022, as has the standard method, the 5 year land supply, the uplift for affordability, and for the 20 largest towns and cities. This plan should only accept provision for other authorities on a voluntary case by case basis, at the plan review stages, after at least 5 or 10 years when we will have accurate information about real population growth and housing need.
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The letter from the Secretary of State of 5 Dec 2022 to Conservative MPs removed the duty to cooperate, removed the requirement of the standard method, removed the 5 year land supply requirement. The local plan should explicitly enshrine these freedoms in the new local plan and state that housing needs from outside Warwickshire will only be accepted on a voluntary basis by the local authorities, on a case by case basis.
Hill Residential welcomes that there is acknowledgement that the SWLP may need to meet the shortfalls of neighbouring authorities in addition to the existing commitments to 2029 (CWHMA) and 2031 (GBBCHMA). The Councils should take positive steps to include provisions in the SWLP that will meet a contribution to the identified shortfalls to ensure that development can, wherever possible, take place in accordance with the spatial strategy that has been set out. The Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Housing Need and Housing Land Supply Position Statement (December 2021) stated that circa 6,000 homes of the Birmingham City Council’s (BCC) shortfall (identified in the 2017 Birmingham Development Plan up to 2031) remain unaccounted for. BCC are now progressing their Local Plan Review, based the latest Housing and Economic Land Availability Assessment (HELAA) there is a potential significant shortfall of 78,415 homes during the plan period (up to 2042). Whilst 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. Coventry City Council are also preparing their Local Plan Review. The scale of any shortfall is unknown at present, however the HEDNA (November 2022) identifies a significant annual housing requirement of 1,964 (based upon the 2021 trend-based projection). Both Birmingham and Coventry have significant constraints on growth within their administrative boundaries. They both have tightly drawn boundaries with limited non- Green Belt options for growth. WDC and SDC should accommodate an appropriate proportion of the emerging GBBCHMA housing shortfall to 2042 and, once established, also accommodate an appropriate proportion of the emerging CWHMA housing shortfall. It is considered that the HMA authorities should determine their respective shortfalls and agree an approach to distributing the shortfall across the HMA area as soon as possible. The approach to the BCC shortfall should be avoided, as set out above there is still a remaining circa 6,000 homes arising from the 2017 shortfall that is unaccounted for. The lack of apportionment of shortfall across the GBBCHMA has resulted in significant delays in plan making across the region, with North Warwickshire being the only authority to adopt their plan following the adoption of the Birmingham Development Plan in 2017. Hill Residential consider that the CWHMA approach to a Memorandum of Understanding (MoU) in 2017 proved to be a successful approach to dealing with the shortfall and enabling authorities to progress with Plan Making – with the last local plan being adopted in June 2019. It is recommended that the south Warwickshire authorities push for such a proactive approach through this next round of shortfall discussions.
In relation to how best to accommodate any shortfall, it would appear logical to locate any housing closest to where the shortfall is arising – in areas to the north of the South Warwickshire plan area.