Issue and Options 2023
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New searchCPRE's submitted report explains why the level of shortfall (or unmet need) arising in Birmingham is exaggerated. It attaches CPRE West Mildands Region's report on the Birmingham Plan Review Issues & Options and the Birmimngham HEDNA (2022). The SWLP Issues & Options consultation papers refer to a 37,900 houses shortfall (to 2031) in the Birmingham Plan as established. This is out of date and incorrect. According to the 2020 Joint Statement on Housing Need and Supply (GBBCHMA I), in the two years since adoption in 2017 (up to 2019), sites for 13,942, or 27% additional housing supply has been found in Birmingham. This shows, among other things the impact of under-estimating windfalls in a local plan. Within two years the shortfall, even if everything else is correct, has been found to fall to 23,958 dwellings, only 63% of the figure in the Plan. By the 2021 addendum (GBBCHMA II) this had risen to an additional 16,071, or 31% of supply, reducing the shortfall to 21,829, (58% of the shortfall) so one would expect it to fall further. The current Birmingham Plan Issues and Options work continues to undercount likely windfalls as well as exaggerating households in Birmingham (demonstrated by comparison of its projected figures with actul population in the 2021 Census). It may fall again when updated ONS figures feed into the next iteration of the plan. Detailed comments on the supposed short fall of 78,415 in Birmingham from WM CPRE are attached as an appendix to our report on Housing Need and Supply and demonstrate the weakness of the case for an overspill. Similarly, the previous shortfall associated with the (now abandoned) Black Country Plan is not consistent either with the 2021 Census results, or with the recent (Chilmark) report on brownfield capacity in the Black Country. Both are addressed in CPRE WM's report (also appended) on the Regulation 18 consultation which was reached, before work on that Plan ceased. CPRE considers it likely that when the individual Plans of the four Black Country boroughs emerge the shortfall in the Black Country area will look very different and may not exist at all. In other words, we do not believe the SWLP should provide any additional land for that unmet need. Indeed, if it were to seek to allocate Green Belt land for housing development, then exceptional circumstances would not exist.
For the reasons given in CPRE's submitted report and the analysis of housing numbers included in the two supporting appraisals (Birmingham Plan Review (I&O) and the Black Country Plan (abandoned at Reg 18 stage), we do not consider that there are housing shortfalls from either that will need to be accommodarted in South Warwickshire.
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CPRE Warwickshire supports the option of using brownfield land for development. We stress that much of this comes through windfalls - planning applications for new housing or conversions to provide additional dwellings. 'Brownfield' and 'windfalls' are not the same, although some windfall housing is approved and delivered on what would be regarded as 'brownfield' - former industrial and commercial sites. The Urabn Capacity Study is a valuable source for proposed ways to use brownfield land and increase density of development in urban areas and in some villages. CPRE's submitted report on Housing and Employment Land Needs includes more detailed appraisal of the UCS.
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The report submitted by CPRE Warwickshire identifies that the housing supply is underestimated because windfalls and some other urban development will be higher than the amount that the Issues & Options is based on. The need for new settlements of any kind is less than the I&O suggests. The actual picture is that there are partial new settlements in the adopted Stratford Core Strategy which have made only limited progress. These are Meon Vale (Long Marston Depot or LMD), Long Marston Airfield (LMA), and Gaydon-Lighthorne Heath (GLH). There are two 'half-settlements close to each other, both approved for some development, Meon Vale and LMA. The Core Strategy in 2015-16 mistakenly failed to promote and allocate a single new settlement (LMD) and instead has ended up with two half-size settlements. This should be remedied by reducing LMA to what has detailed planning permission and focussing on LMD which has the scope for a full range of services if made larger. LMD is suitable for a rail service (it has a line); LMA is much more difficult to serve by rail. GLH has hardly started development, and is supposed to have 3,000 houses. There is no case for any more new settlements. Rail corridors as presented as a Growth Option do not make sense. Some of the lines are in the Green Belt; they serve villages in the Green Belt but these locations are unsuitable as expanded or new settlements. The rail corridor that should be developed is from Coventry to Honeybourne on the Cotswold Line, with stations at Warwick University, Kenilworth (now open), Milverton (reopen), Leamington, Warwick, Wilmcote, Warwick Parkway, Stratford Parkway, Stratford-upon-Avon, and Long Marston, and at Honeybourne continuing to Evesham and Worcester. The sections now single-track should be doubled and the missing section between Stratford and Long Marston reinstated. This route would link up the main urban centres in the SWLP area and enable the best-located new settlement under way (Meon Vale / LMD) to develop effectively.
The report submitted by CPRE Warwickshire identifies that the housing supply is underestimated because windfalls and some other urban development will be higher than the amount that the Issues & Options is based on. The need for new housing allocations in or adjacent to villages is not established. Recent rates of permission on new sites around some villages beyond the Green Belt in Stratford District have been harmful to the villages, their settings, and the countryside beyond. Windfalls - new houses within village envelopes which meet design criteria and comply with planning policies, and receive permission - are the way in which villages can grow within their limits. A 'dispersal strategy' would also be unsustainable by increasing populations who are dependent on private cars for all travel and accessing services.
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