Issue and Options 2023

1. WINDFALLS • The SWLP allows for land for 220 dwellings per annum (DPA) from windfalls. • Actual annual average windfall numbers since 2011 have been 901. • 69% of Stratford’s housing site needs since 2011 have been met from Windfalls; 44% of Warwick’s. • If instead of 220 DPA’s (as in plan) the SWLP assumed only half the annual average, (450 homes) the housing land shortfall drops from 23,000 to 1510 in 2040; 5,410 in 2045 and 9310 in 2050. • If the actual average since 2011 – 901 - is used, the plan is in surplus: 5,255 excess house spaces in 2040; 3610 excess in 2045. 1965 in 2050. • In addition to a severe underestimate of overall numbers, the Local Planning guidance only includes within the 220, those spaces for fewer than 9 dwellings. So places like the Ford Foundry site, the King’s High School sites, land adjacent to Leamington Spa Station, and others for more than 9 houses would not be included. • We believe that this also seriously distorts likely available land, based on figures since 2011. 2. AFFORDABILITY UPLIFTS • Under a formula devised in 2004, housing numbers are automatically increased in more expensive areas, on the assertion that building more houses will bring down prices. • This has nothing whatsoever to do with actual housing need. • ONS numbers from the base year used (2014) assessed the SWLP area need at 874 homes. The Affordability formula increases this to 1,239. These are the numbers used in the SWLP. • This is an increase of 42% over need. 3. IN-MIGRATION • Housing numbers like Coventry’s encourage net in-migration to local areas. They are not a response to endogenous growth. • 76% of Warwick’s estimated population growth for 2018-2028 comes from net in-migration. • 118% (!) of Stratford’s is from the same source. • This therefore risks becoming a self-replicating cycle. (“We’ve filled more houses, therefore we need more houses, therefore…”) 4. DUTY TO CO-OPERATE • Housing was built in the SWLP area as a response to Coventry’s overestimates, destroying swathes of prime farmland in the process. • This is part of the ‘Duty to Cooperate’ imposed on neighbouring areas, when the ‘growing’ area does not have the requisite space. • The government has added 35% to assessed need in 20 key cities. (In theory this means that more urban brownfield sites are used.) Applying this to Birmingham gives them three times their demographic need. • Birmingham does not have space for these numbers. • This potentially means that over the plan period South Warwickshire will have to build houses they don’t want for a Birmingham need that doesn’t exist. • The Black Country has currently paused its Local Plan for similar reasons. 5. EMPLOYMENT LAND NEEDS • We would ask those responsible for the SWLP to reconsider Employment land needs. • Numbers don’t reflect the estimated 30% reduction in office space post-Covid. • There is also a visible increase in Town Centre vacant retail sites across the region. • In particular, Stratford is estimated to need 132.8Ha (333 acres) of Industrial Land. • This puts it only behind Rugby (Cement and extraction) and Coventry (automotive). • We have asked for an explanation of how this number was derived. 6. TIMEFRAME • The SWLP framework extends from 2025 to 2050, to allow for long-term infrastructure planning. • This is considerably longer than most planning frameworks. • Increasing the plan from the more usual 15 years, increases SWLP housing numbers by 50%. (And therefore countryside blight). • Remaining with 15 years, instead of 35,000 houses by 2050 we would be looking at 23,370 by 2040.