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ID sylw: 105979

Derbyniwyd: 06/03/2025

Ymatebydd: Nick Chambers

The housing “needs” set out in Table 2 (HEDNA method) and Table 3 (2024 NPPF standard method) have little in the way of justification. The Opportunity Areas identified in WMSESS are primarily clustered in North Warwickshire and counties further north; whilst those Areas 7 (Coventry & Rugby), 8 (M40/A46), and 9 (Redditch & Bromsgrove) closer to South Warwickshire are much less favourable and therefore unlikely to attract business investment. Their projected level of employment is small, and relevant only to the northernmost areas of Stratford-on-Avon. With a need for housing to be located close to employment, it is inappropriate and unreasonable to group all of South Warwickshire into a single region.

Indeed, South Warwickshire is noted as having “a more service-orientated economy and higher housing costs”, in line with its more rural nature and much lower population density.

The 2014-based projections for Stratford-on-Avon given in Table 3.1 of the HEDNA Executive Summary 171122 is for 564 houses. Section 3.6 goes on to state that “it is reasonable and expected that any alternative trend-based projection would show a lower need” and Section 3.7 argues that employment growth is slowing and that “there is therefore no case for adjusting upwards overall housing need.”

However, this conflicts with Table 2 (HEDNA method) that seeks to increase the housing needs from 564 to 868 houses, an increase of over 50% ! The only justification given is “unmet needs from Birmingham and Coventry & Warwickshire”. However, as stated on page 43, “Until there is greater certainty regarding the quantum of unmet needs from neighbouring housing market areas, it is premature to allocate reserve housing sites. The latest evidence and further discussions with neighbouring authorities will inform the Regulation 19 Submission policies on unmet housing need. If reserve housing sites are needed, the SWLP process will consider suitable sites which may include draft reserve housing allocations in Stratford-on-Avon District Council’s Site Allocation Plan (SOADC SAP).”



Furthermore, given the lack of sustainable transport infrastructure between South Warwickshire and Birmingham/Coventry, then it is completely unreasonable to argue that housing in South Warwickshire should meet the needs of Birmingham/Coventry. These areas are closer to other county districts than to South Warwickshire, particularly when enabling road infrastructure is taken into consideration.

It is therefore even more unreasonable in Table 3 (2024 NPPF standard method) to propose a target of 1126 houses within Stratford District, which is DOUBLE that of the 2014-based projections. This level of housing demonstrably cannot be supported by local employment opportunities. Indeed, reference is made to Abbey Park in the Warwick District that “has faced deliverability challenges since consent and questions remains around the market attractiveness of the site in terms of its rural locations”. This observation is a clear market signal around the problems of creating employment opportunities in rural locations.

The housing needs for Stratford-on-Avon should be based upon figures much closer to the 2014-based projections of 564 houses per annum. This can be met from existing commitments and windfall allowance, and therefore reduces the To-Find figure for Stratford-on-Avon to zero.