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?
South Warwickshire should under no circumstance choose to take more additional growth, this would put additional serious pressure on services, infrastructure, important habitats and environments in the area. The other Councils need to legitimately look to find land/ increase housing densities in their local areas. Especially as it would appear Birmingham has copious brown field sites which could be utilised which would be preferable to using green belt land. Under no circumstance should Warwickshire take on the shortfall off other areas.
We should not and appropriate strong objection is needed against this. If Stratford Council fails in this and is forced then more high quality duplex flats should be built with decent sound proofing, balconies, roof terrace/garden space. As we do not have enough land in the UK to allow for agriculture, wild space and enough housing we need to be utilising our air space more. Flats would be more desirable in the UK if they were built properly. We can not continue with everyone’s wish for a 4-bed detached house with a garden. There is not enough room.
Q H4.1 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.
No answer given
In accordance with the guidance contained within the Framework, development should be focussed in the most sustainable locations in terms of availability of shops, facilities and services, as well as access by modes of transport other than the private car. In addition, it is considered that development should be distributed over a range of settlements rather than in single settlements in order to ensure their vitality and viability in accordance with the principles of sustainable development set out in the Framework.L&Q Estates consider any housing shortfalls from outside of South Warwickshire should be directed to sustainable locations in accordance with the distribution of development established in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy. Alcester is identified as one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-on-Avon district. It offers a large range of services and facilities, including a selection of independent and high street shops, a Post Office, Public Houses, supermarkets, churches, hotels, GP surgeries, veterinary clinic and a leisure centre. Land South of Allimore Lane, Alcester is located immediately east of the A435 and adjoins the built-up area boundary of Alcester and existing residential development to the north and east. The site is contained by the A435 to the west and would form an enduring definition to the built-up area boundary. The promotion site would be well connected to the built-up area of Alcester, a Main Rural Centre with many local services, and would constitute sustainable development. Indeed, it is considered that the new homes at Land South of Allimore Lane will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Alcester’s services and facilities. Given the pressing need for additional housing within the Stratford-on-Avon District, in addition to meeting the housing shortfalls from outside of South Warwickshire, Alcester is clearly a sustainable location to accommodate additional housing growth. The Site at Land South of Allimore Lane, Alcester 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-H4-1: 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.
It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF. It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. Bellway consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (i.e. Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above Bellway consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050, leaving a potential shortfall of circa 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases, an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.
No answer given
Q-H4.1: Gladman agree with the approach to contributing to meeting unmet need from Birmingham and Black Country on the identified sites in Stratford-on-Avon. However, the unmet need from Birmingham has risen since the allocated sites were adopted, therefore the Councils should ensure that they are considering their contribution to the most up-to-date unmet need figure. Q-H4.2: The Councils should ensure that they are discussing the apportionment of unmet need with neighbouring authorities through the DtC in order to address the most upto-date unmet need figures. The adopted Stratford-on-Avon Plan recognises the socio-economic links between Birmingham and Stratford-on-Avon and given the early stage of this Plan, Gladman consider that this is an ideal opportunity to determine the level of unmet need to 2050 and make a meaningful contribution to the delivery of these much needed homes. The current identified shortfall for Birmingham stands at 78,415 homes based on the standard method, and though the Black Country Plan has since been abandoned, the unmet need was forecasted to be between 28,000-39,000 homes, dependent on the scale of Green Belt release. A total unmet need of circa 100,000 homes is not insignificant and Gladman urge the Councils to work closely with neighbouring authorities and collaborate with developers to identify the most sustainable and appropriate for these unmet needs to be met. The Councils may be aware that the Inspectors for the Shropshire Examination in Public have issued interim findings regarding a number of matters raised in the Stage 1 Hearing Sessions in July last year. Of utmost importance are the comments regarding the breakdown of the Black Country Joint Plan, whereby the Inspectors state, ‘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’ and that ‘it remains an important strategic cross boundary matter that should not be deferred.’ This makes clear that the unmet housing needs of the HMA have not and will not simply fall away and the Councils should continue to take a pragmatic approach to this strategic cross boundary issues.
Gladman considers that the Council should seek to provide land to meet their housing need and an appropriate level of unmet need from Birmingham and Black Country and Coventry. This is likely to mean that all options need to be explored. Gladman would support the Council in considering the Green Belt boundaries once all suitable land has been considered, and identifying exceptional circumstances to ensure that the housing need is met through an appropriate spatial strategy.
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. 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. Sharba Homes broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 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.
It is considered that any unmet housing need arising from either the Greater Birmingham HMA or from elsewhere within the Coventry and Warwickshire HMA (or indeed any other HMAs in need) should be met in locations accessible to those HMAs, in accordance with the established growth strategy (disbursed approach). This is likely to result in directing additional growth to the north of the Plan area and adjacent to the administrative area of Coventry to meet unmet housing need. As such, in order to avoid any additional pressure on this part of the Plan area, it is considered that local housing need should be focussed on the remainder of the Plan area, in accordance with the growth strategy (disbursed approach).
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. 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. Sharba Homes broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 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.
It is considered that any unmet housing need arising from either the Greater Birmingham HMA or from elsewhere within the Coventry and Warwickshire HMA (or indeed any other HMAs in need) should be met in locations accessible to those HMAs, in accordance with the established growth strategy (disbursed approach). This is likely to result in directing additional growth to the north of the Plan area and adjacent to the administrative area of Coventry to meet unmet housing need. As such, in order to avoid any additional pressure on this part of the Plan area, it is considered that local housing need should be focussed on the remainder of the Plan area, in accordance with the growth strategy (disbursed approach).
Q-H4-1: The plan should take account of cross-boundary requirements prior to 2031 and beyond. It is unclear why the question specifies either ‘on identified sites’ or Stratford-on-Avon District alone. Q-H4-2: This should preferably be based on agreed outcomes arising from discussions by the authorities concerned. If there is no agreement, then past migration trends should be used as the basis for distributing any cross-boundary requirements.
In the past development capacity closer to the origin would have been emphasized. In the light of changing work patterns and a higher propensity to work from home a loosening of that approach might be more appropriate.It is also appropriate to bear in-mind that migration moves are made within the housing stock and not just new-build, so the existing stock can still enable migrants to live close to their point of origin should they wish to do so. Our client’s land at Chessetts Wood Road is well-placed to help meet housing needs arising in the conurbation.
We agree that the Local Plan should contribute to meeting housing needs arising from outside South Warwickshire.
Shortfalls should be accommodated in the most sustainable locations closest to the area from which the need derives. This may be within the Green Belt.
QH4.1Do 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 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. QH4.2Please 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 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)
No answer given
Q H4.1 An accurate assessment is needed to establish how much land is available within Birmingham before taking green field sites outside the city. For example the old Longbridge works was demolished and new retail facilities were built. Very few houses were provided. Several thousand houses could have been built. All the facilities were available, schools, transport, medical care, employment all within a reasonable distance. Moving people out into the countryside which does not have the infrastructure to support that movement is just wrong.
No answer given
Issue H4: Accommodating needs arising from outside South Warwickshire 56. The consultation explains that the total amount of housing that the Local Plan will also need to include the provision of an agreed proportion of any need from Greater Birmingham & the Black Country and from Coventry that cannot be accommodated within those areas. 57. As noted previously the HBF agrees that South Warwickshire Plan should include housing to meet the unmet needs of neighbouring authorities. To assist in the understanding of the calculations used, the HBF suggest that unmet needs of each area (Birmingham and Black Country and Coventry) should be considered separately. The quantum of unmet need from each area needs to be clearly set out. Where the unmet need arises from may affect how best that unmet need could be met. 58. The HBF notes the latest position statement on Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Position Statement Addendum (Dec 2021). Although the HBF welcomes this work, it should result in a signed Statement of Common Ground (SoCG) which clearly sets out how the unmet of Birmingham and the Black Country will be redistributed. To ensure delivery of the housing needed the South Warwickshire Authorities will need ensure this engagement remains ongoing. It will be important to understand the level of unmet need that South Warwickshire is required to accommodate in order to properly consider how to meet this element of unmet need within the Plan. 59. Similarly, a signed statement of Common Ground will be needed that clearly sets out the unmet needs of Coventry and how this will be redistributed. As the adopted Coventry Local Plan covers only the period of 2011-2031 additional work will be needed to robustly evidence the level on unmet need in Coventry, and how this will be accommodated across the whole South Warwickshire plan period. It will be important for this information to be kept under review and for the most up to date data to be available for the Local Plan preparation as it progresses. 60. The HBF agrees that meeting unmet housing needs which occur neighbouring HMAs is a cross boundary matter. To fully meet the legal requirements of the Duty to Co-operate the Councils should engage in a constructive, active and on-going basis with their neighbouring authorities to maximise the effectiveness of plan making. One key outcome from co-operation between the neighbouring HMA authorities should be the meeting the full housing requirement for each HMA.
61. The meeting of unmet needs should be set out in a Statement of Common Ground signed by all respective HMA authorities. The HBF would suggest that the SoCG on Unmet Housing Need should confirm that: • Each authority will meet its own LHN and a defined amount of the unmet local housing need (LHN). • This cumulative figure will be the housing requirement figure for each authority respectively; and • The authorities acknowledge that additionality in HLS may be required to ensure deliverability and flexibility
Q-H4-1 to H4-3 Braemar supports the principle of unmet needs from the Birmingham and Black Country HMA being met within South Warwickshire.
No answer given
No answer given
3.13 The incorporation of any shortfall housing numbers should be informed by the wider South Warwickshire strategy. It is noted that existing shortfall is focussed on Stratford-upon-Avon. Any additional numbers should incorporate an aspect of the dispersed option as highlighted in the response to question S7.2. Settlements such as Long Marston have the ability to provide small levels of growth to support local services and facilities, ensuring South Warwickshire can meet its housing requirements.
Q-H4-1: Yes. The plan should take account of cross-boundary requirements prior to 2031 and beyond. It is unclear why the question specifies either ‘on identified sites’ or Stratford-on-Avon District alone. Q-H4-2: This should preferably be based on agreed outcomes arising from discussions by the authorities concerned. If there is no agreement, then past migration trend should be used as the basis for distributing any cross-boundary requirements.
Q-H4-3: In the past development capacity closer to the origin would have been emphasized. In the light of changing work patterns and a higher propensity to work from home a loosening of that approach might be more appropriate. It is also appropriate to bear in-mind that migration moves are made within the housing stock and not just new-build, so the existing stock can still enable migrants to live close to their point of origin should they wish to do so.
Q H4.1 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.
WCC would like to better understand if any requirement to meet the Birmingham and Black country HMA (housing market assessment) shortfall would apply to specialist supported housing needs, and if so, then request an opportunity to engage further on this and related questions.
Any additional housing requirement should form part of the overall housing number. Growth to be located as close as possible to the overspill area.
Q-H4.1: 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: 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). 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.
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. For the reasons explained under Q-S5.2, the Respondent would caution the Council 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.
No answer given
The new emerging SWLP timeframe will extend from potentially the years 2030 up until the year 2050. In terms of meeting housing shortfalls from elsewhere and deciding where to focus this new housing development within the emerging SWLP area, the future housing development growth needs of existing rural village settlements across the SWLP Plan area, and the new housing-led development expansion needs of these existing rural village settlements will therefore require careful consideration given the considerable timeframe of the new Local Plan, extending up until the year 2050. Existing village settlements, such as the Village of Broom, should therefore be given very high priority, and should be urgently prioritised for new housing development. This matter should not be left for a Stage 2/ version 2 of the SWLP Review to consider in many years from now, but should be prioritised as a matter of urgency now within the January 2023 SWLP. In particular, in terms of considering how these existing rural village settlements (like the Village of Broom) can grow and thrive over the new Local Plan period by bringing forward sustainably located new housing development sites, such as the sustainably located Lockley Homes site currently being promoted through the emerging SWLP. The future growth and sustainable expansion needs of existing rural village settlements across the SWLP area will therefore require careful planning policy consideration to help shape their future development needs up until the year 2050. Particularly, the sustainable expansion of existing rural village settlements on the edges of their existing boundaries with new housing, the policy approach strongly promoted by guidance in paragraph 79 of the Revised NPPF (2021) as considered below. As this spatial planning approach can help to sustain the vitality of existing rural village settlements with new sustainably located housing, allowing them to grow and thrive over the future years. Paragraph 79 of the Revised NPPF (2021) states that: “…To promote sustainable development in rural areas, housing should be located where it would enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive…” Before promoting ‘free-standing’ sites located within the open countryside, including those ‘free-standing’ sites located within the existing designated Green Belt countryside, the emerging Stratford-on-Avon District Council emerging Site Allocations Plan (SAP) (Review) (2023) and Stratford-on-Avon and Warwick District Council’s emerging South Warwickshire Local Plan (SWLP) Reviews should be strictly prioritising the delivery of new housing development sites within sustainably-located large infill sites (located outside of the designated Green Belt), located within existing rural village settlements. And prioritising the delivery of new housing development within areas of farmland located on the edges of existing rural village settlements. The evidence is perfectly clear, this approach to Plan-making is strongly supported by guidance reinforced within paragraphs 11, 35 (indent d), 79, 120 (indent d), 141 (indent a), 142 and 149 (indent e) of the Revised NPPF (July 2021). To follow a different Plan-making approach would fail the ‘Sustainability’ tests of Soundness for Local Plan preparation as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021), and would make the emerging SAP and SWLP Local Plan Reviews, and any supporting background technical evidence base being used to accompany Plan-preparation, insufficiently robust, and therefore vulnerable to future Legal challenge at the later Local Plans Examination in Public (EIP) stages. We have concerns about the longstanding failings being taken towards Local Plan preparation within the Stratford-on-Avon District on these matters, and Stratford-on-Avon District Council’s constant ongoing refusal to promote the most sustainable patterns of new housing development within the Stratford-on-Avon District. We have concerns about the “incapable” management and leadership approach being taken towards Local Plan preparation within the Stratford-on-Avon District given the Council’s Planning Policy Teams continued refusal and ongoing failure to promote the most sustainable patterns of new housing development within the emerging SAP Local Plan Review (2023). This underlines the ongoing failure and continued incompetence being taken towards Local Plan preparation within the Stratford-on-Avon District. These ongoing failings are already covered in detail within our Representations to Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (Review) (2022). Paragraph 120 (indent d) of the Revised NPPF (2021) confirms that: “…Planning policies and decisions should: (indent d) promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example converting space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure) …” Paragraph 141 (indent a) of the Revised NPPF (July 2021) underlines the importance and expects LPA’s to encourage the use of under-utilised land for new housing development. Such as low-quality green space areas and derelict and under-utilised former paddock land, located both within and bordering existing rural village settlements - in order to help promote the most sustainable site locations for new housing development. It emphasises that these highly sustainable site locations should be prioritised first for new housing development. Before LPA’s introduce changes to Green Belt boundaries and before LPA’s identify sites for new housing development within the Green Belt countryside. This spatial planning policy approach to Local Plan-preparation is required in order to help protect the Green Belt from development encroachment pressures, and to help promote sustainable patterns of development as stated above. It states that: “… Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy: (indent a) makes as much use as possible of suitable brownfield sites and under-utilised land…” Further support is provided in paragraph 142 of the Revised NPPF (2021) which is perfectly clear in its view that: “…When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policy-making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land…” These types of highly sustainable infill site locations (see photographs 1 and 2 in Appendix B of this Representations Statement document (March 2023), should be strictly prioritised first as a matter of urgency for new housing development. Before LPA’s select unsustainable site locations for new housing development, located within areas of open Green Belt countryside. In free-standing new build housing settlements, located far away from existing rural village settlements, and far away from existing towns. Competent Local Planning Authorities should ensure that their emerging Sustainability Appraisals (SA’s), being prepared alongside/ to support emerging Local Plan Reviews, should take on board these critically important spatial planning policy considerations - consistent with guidance in paragraphs 11, 35 (indent d), 79, 120 (indent d), 141 (indent a), 142 and 149 (indent e) of the Revised NPPF (2021). This will help to ensure that Local Plan Reviews satisfy the Local Plan ‘tests of Soundness’ (Para 35 – indent d of the Revised NPPF (2021)) when these tests of soundness are being carefully examined at future Public Local Inquiries (PLI’s), as part of the Local Plan Review preparation stage. Lockley Homes maintains its view that it has a sustainably-located site suitable for new housing development, located within an existing rural village settlement boundary. Given the very strong, defendable, clear and compelling sustainability credentials of the site as already evidenced in our earlier Representations to both the SWLP and SAP Local Plan Reviews. We consider that this site, within the Village of Broom settlement boundary, should be prioritised for future development, and included without delay as a new housing site allocation on the main Policies Map of the emerging Local Plan Reviews referred to above. This site should also be strongly encouraged within the emerging background technical evidence base documents being used to support Local Plan preparation work across the South Warwickshire Region, given this sites very strong set of sustainability credentials. This is particularly evidenced in photographs 1 and 2 of Appendix B of this Representations Statement (March 2023). We consider that allocating this site for new housing development in the Council’s emerging SAP and SWLP as suggested, would result in a More Effective, Positively Prepared and Justified Plan, consistent with guidance in paragraph 35 of the Revised NPPF (2021).
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: 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 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.
In accordance with the guidance contained within the Framework, development should be focussed in the most sustainable locations in terms of availability of shops, facilities and services, as well as access by modes of transport other than the private car. In addition, it is considered that development should be distributed over a range of settlements rather than in single settlements in order to ensure their vitality and viability in accordance with the principles of sustainable development set out in the Framework. L&Q Estates consider any housing shortfalls from outside of South Warwickshire should be directed to sustainable locations in accordance with the distribution of development established in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy. Long Itchington is identified as a Category 1 Local Service Village and is therefore one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-on-Avon district. It offers a large range of services and facilities, including a supermarket, a small local shop, a nursery and primary school, seven pubs, a diner, hairdressers and allotments. Land north of Leamington Road, Long Itchington is located along the northern edge of the village and immediately adjoins the built-up area boundary of Long Itchington and existing residential development to the south. The promotion site would be well connected to the built-up area of Long Itchington and would constitute sustainable development. Indeed, it is considered that the new homes at land north of Leamington Road will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Long Itchington’s services and facilities. Given the pressing need for additional housing within the Stratford-on-Avon District, in addition to meeting the housing shortfalls from outside of South Warwickshire, Long Itchington is clearly a sustainable location to accommodate additional housing growth. The Site 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 village 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.
National Highways would welcome early engagement with the local planning authorities and local highway authorities to identify the quantum of the Birmingham and Black Country HMA shortfall which would be accommodated within South Warwickshire and assessed through the strategic transport assessment that would support the development of the forthcoming local plan.
No answer given
There is concern for the amount of green belt being swallowed up for new developments. Why should land east of Kenilworth be designated for Coventry overspill? Could not more brownfield sites be utilised for this or indeed other land around Coventry. There is a case for Kenilworth becoming joined up to Coventry if planning is not looked at more carefully. This again has huge ramifications for its individuality and attractiveness. In general too much new development around Kenilworth will affect the infrastructure of the town. Large increases in population because of new housing will have a detrimental affect on existing roads, parking, doctor's surgeries, schools, shops, policing, hospitals
No answer given
No answer given
No answer given
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 appears to have 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. QH4.2: 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 plan-making 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 with 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.
Unmet Housing Need Arising from Outside South Warwickshire 3.15 As the SWLP notes, neither the Standard Method of calculating local housing need, nor the revised trend-based calculation detailed within the HEDNA (2022), take account of the provision of unmet need arising from outside of South Warwickshire; namely, from within the Greater Birmingham and Coventry & Warwickshire Housing Market Areas. 3.16 South Warwickshire lies fully within the Coventry and Warwickshire HMA, and Stratford-onAvon district also lies within the Greater Birmingham and Black Country HMA. The HEDNA (2022), published as part of the plan’s core evidence-base, affirms the conclusion that both the Greater Birmingham and Black Country HMA and the Coventry and Warwickshire HMA remain appropriate to the determination of housing need for South Warwickshire. In particular, the HEDNA (2022) states that Stratford-on-Avon District: ‘...will therefore need to consider unmet needs from Birmingham in setting housing targets within their respective local plans alongside any unmet needs from within the Coventry & Warwickshire HMA’ 3 . 3.17 Further supporting this conclusion, the draft plan clarifies that officer-level discussions have taken place between the relevant Councils that comprise the Greater Birmingham and Black Country HMA and the Coventry and Warwickshire HMA, as part of the Duty-to-Cooperate, to discuss the position regarding unmet need across the sub-regions. 3.18 The SWLP confirms that there are four sources of unmet housing need that may have implications for South Warwickshire: 1. Shortfall from the Greater Birmingham and Black Country HMA to 2031 2. Shortfall from the Greater Birmingham and Black Country HMA to 2050 3. Shortfall from Coventry to 2050, and 4. Shortfall from other HMA areas to 2050. 3.19 Together, these sources are expected to provide a substantial level of unmet housing within the region that needs to be accounted for within the South Warwickshire Plan. 3.20 In Stratford-on-Avon’s emerging Site Allocations Preferred Options (June 2022) Development Plan Document, Proposed Policy SAP.4 identifies several sites, with a total capacity of approximately 380 homes, which will be released to provide Stratford-on-Avon District’s contribution to meeting the shortfall in dwelling provision in the Greater Birmingham & Black Country HMA. Further to this provision of unmet housing need up to 2031, Stratford-on-Avon District will need to take account of Birmingham City Council’s Local Plan Review to 2042, which has identified a shortfall in housing of 78,415 homes in the Council’s recent Issues and Options consultation4 . 3.22 In addition to this, as noted within the SWLP, further unmet need may also be identified as arising from the other Black Country authorities. To address the shortfall arising within the Greater Birmingham and Black Country HMA, South Warwickshire (in particular Stratford-onAvon district) should seek to contribute as significant a proportion of the existing identified unmet need as reasonably practicable. Furthermore, the SWLP confirms that, even considering the redistribution of housing resulting from the trend-based projection, Coventry is unlikely to be able to accommodate all of its housing needs (1,964 homes per annum), and as such a shortfall may exist to 2050, which South Warwickshire will need to do its part in addressing
4 In meeting the substantial level of unmet need arising from outside of South Warwickshire (‘SW’), the SWLP identifies that preference should be given to accommodating that unmet need within the appropriate district relating to the source of need arising. For example, unmet need arising from the Greater Birmingham and Black Country HMA should be met within Stratford-on-Avon district as far as is reasonably practicable. 3.25 However, the western extent of the SW area, which is closer to where the unmet need arises, remains relatively constrained and is considered unlikely to represent the preferred location for development once these constraints are considered in the development of the spatial strategy. To assist in meeting this need, the SWLP should consider a dispersed approach to development in South Warwickshire, reflecting the existing historic pattern of development in the region and supporting the vitality of rural communities. 3.26 In summary, Kingacre supports the Councils’ commitment to meeting South Warwickshire’s minimum local housing need in full (whether calculated using the 2014-based population projections or the HEDNA trend-based projections), alongside an appropriate proportion of the unmet need arising from outside South Warwickshire. 3.27 The Councils’ constructive engagement with their neighbouring authorities toward understanding the position regarding unmet need within the HMA and, consequently, toward establishing the extent to which the district could appropriately contribute toward meeting that unmet need, is supported. 3.28 Kingacre recommends that the opportunity presented within the South Warwickshire plan, to contribute as significant a proportion of the identified unmet need as reasonably practicable, is taken forward when considering the appropriate Housing Requirement for the Districts. Section 33a of the Planning and Compulsory Purchase Act 2004 requires local planning authorities to co-operate with other authorities, the relevant County Council, and prescribed bodies or other persons, in relation to the preparation of the Plan. The Duty requires the Council to engage constructively, actively, and on an on-going basis, in the preparation of the Plan, in so far as it relates to a strategic matter. A strategic matter includes the sustainable development and use of land that has, or would have, a significant impact on at least two planning areas. 3.30 Government policy, set out in paragraph 26 of the NPPF, states that effective and ongoing working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. It goes on to state, in particular, that joint working should help determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere. Co-operation, therefore, is about maximising the effectiveness of plan preparation. 3.31 As noted previously, Kingacre welcomes the Councils’ commitment to meeting unmet need as part of this process. However, upon closer inspection, published evidence of regular ongoing meetings with the above bodies does not appear to be available. 3.32 In relation to the Coventry & Warwickshire HMA, the archive of meetings5 shows that there has not been a meeting since November 2019, and that the preceding meeting that had taken prior to this was in November 2018. Prior to this November 2018 meeting, meetings appear to have been taking place 3 – 4 times per annum. 3.33 With regard to the Greater Birmingham & Black Country HMA, the published evidence comprises a series of Housing Need and Housing Land Supply Position Statements, issued in 2018 (both February and September), September 2020, and the most recent in December 2021. 3.34 The 2020 Statement notes that ‘Detailed consideration of where need can be met is ongoing across the authorities and refers to the initial piece of work undertaken in 2018 known as the Greater Birmingham Strategic Growth Study’. The Position Statements suggest and demonstrates monitoring of need and supply is indeed taking place. However, there appears to be no published evidence suggesting that active and ongoing co-operation resulting from the monitoring has been and continues to be taking place at regular intervals. Given that one of the main purposes of the document is to ensure the ability to specifically respond to and accommodate unmet housing need generated outside of the SW plan area (but within intersecting HMAs), it would be helpful for the Council to provide further information on the ongoing work and efforts to ensure cross-boundary matters are being proactively and positively taken into account now. 3.36 The Councils will be aware that examining Inspectors have recommended the withdrawal of Local Plans in a number of authorities due to failings in implementing the duty-to-cooperate, including in Sevenoaks District and Buckinghamshire Councils. In recommending these withdrawals, the Inspectors have specifically cited failings regarding the matter of unmet needs in this regard. 3.37 To ensure that the SWLP is considered to be positively prepared and effective, it is recommended that; in addition to the Council continuing to pursue active and constructive engagement with its neighbouring authorities on strategic matters, it is equally as important that the Councils formally publish evidence demonstrating the ongoing engagement at the earliest opportunity. Ideally, this should be undertaken in advance of the next stage of consultation on the SWLP, to ensure it can be reviewed and examined in a timely fashion. The Need for Affordable Housing 3.38 South Warwickshire faces a significant need for affordable housing over the plan period, as affirmed within the SWLP. The conclusions of the HEDNA (2022) further demonstrate the extent of this need in the plan area, finding that there is a need within South Warwickshire for approximately 1,386 affordable homes per annum up to 2050. Specifically, the HEDNA (2022) clarifies that the need for affordable homes (per annum) is 547 for Stratford-on-Avon District and 839 for Warwick District6 . 3.39 Furthermore, the HEDNA (2022) identifies that: “In setting housing targets in individual local plans, the affordable housing evidence is also relevant. In the northern part of the sub-region in particular – in North Warwickshire and Nuneaton and Bedworth - this supports the case for considering, as part of the planmaking process, higher housing provision than shown in Table 15.5 in order to boost the delivery of affordable housing.” 7 . 3.40 The identified need for affordable homes in South Warwickshire, of 1,386 dwellings per annum, comprises approximately 80% of the overall identified housing need for the plan area of 1,792 dpa. In Stratford-on-Avon, the identified need for affordable housing relates to approximately 63% of the overall housing need for the District. The situation is even more challenging in Warwick, where affordable housing need represents 103% of the equivalent identified housing need for the plan period. To deliver the number of affordable homes that are needed in South Warwickshire, the plan would be required to identify a housing supply of approximately 3,465 dpa (assuming a policy requirement of 40% affordable housing provision is taken forward). This represents almost double the proposed identified annual housing requirement, which itself represents a substantially increased rate in relation to the 2014-based Local Housing Need figure. 3.42 Given that the identified annual need for affordable housing provision comprises approximately 80% of the overall annual local housing need, there is a clear case for examining the extent to which further growth could be accommodated within the SW area to promote the delivery of greater affordable housing. 3.43 Furthermore, there is a considerable need to support affordable housing delivery within South Warwickshire’s rural communities. For example, Stratford-on-Avon District’s own evidence-base confirms that there have been no new affordable homes delivered within Priors Marston village over at least the previous decade. 3.44 Clearly, if the services and amenities of Local Service Villages, such as Priors Marston, are to remain viable up to 2050, there is a need to plan for and deliver new market and affordable homes at the Village within the plan period. The Land Adjacent to Grange Cottages, Hardwick Road, presents the most suitable opportunity to provide this within the plan period.
Q-H4.1: The plan should take account of cross-boundary requirements prior to 2031 and beyond. It is unclear why the question specifies either ‘on identified sites’ or Stratford-on-Avon District alone. Q-H4.2: This should preferably be based on agreed outcomes arising from discussions by the authorities concerned. If there is no agreement, then past migration trends should be used as the basis for distributing any cross-boundary requirements.
In the past development capacity closer to the origin would have been emphasized. In the light of changing work patterns and a higher propensity to work from home a loosening of that approach might be more appropriate. It is also appropriate to bear in-mind that migration moves are made within the housing stock and not just new-build, so the existing stock can still enable migrants to live close to their point of origin should they wish to do so.
Q H4.1 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.