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ID sylw: 107242

Derbyniwyd: 07/03/2025

Ymatebydd: Solihull MBC

Meeting Housing Need
The housing need figure for South Warwickshire over the plan period is set out in Draft Policy Direction 1 and is presented as a range reflecting the findings of the Coventry and Warwickshire HEDNA as a minimum and the standard methodology as the top of the range. It proposes the delivery of at least 1,679 dwellings per annum across the area with flexibility to provide up to 2,188 per annum. This equates to 41,975 between 2025 and 2050 with flexibility to provide up to 54,700 dwellings.
A revised National Planning Policy Framework (NPPF) was published on the12th December 2024. This sets out the approach for determining local housing need which expects local authorities to follow the standard methodology for assessing local housing need. It identifies that the minimum annual housing need figure should be based on this approach (Paragraph 62). National Planning guidance sets out that where ‘Local housing need assessments may cover more than one area in particular where strategic policies are being produced jointly. In such cases the housing need for the defined area should at least be the sum of the local housing need for each local planning authority within the area (para 013 Housing and Economic Needs Assessment guidance).
Paragraph 69 of the NPPF sets out that strategic policy making authorities should establish a housing requirement figure for their whole area which shows the extent to which their identified housing need (and any needs which cannot be met within neighbouring areas) can be met over the plan period.
The plan sets out a sustainable spatial strategy for meeting the areas growth needs over the plan period with flexibility to meet the upper end of the identified housing need as evidenced through the standard methodology. This focuses development in priority areas 1 to 3 identifying potential new settlements and 24 potential strategic growth locations. It is clear from the range of potential locations for growth identified in the plan that there is capacity and sufficient flexibility to meet the overall higher need based on the standard methodology as set out in the NPPF. SMBC would support in principle a strategy which seeks to meet the identified housing need within the Local Plan boundary and does not seek to redistribute growth outside of the Local Plan area. Given the capacity to plan for the higher housing need figure it is unclear why the housing need is presented as a range and the higher figure derived from the standard methodology is not identified as the minimum housing need. This would reflect the latest government position for delivering national objectives for housing growth and would ensure the housing needs for South Warwickshire are met.
SMBC welcomes the commitment within the Preferred Options Plan to address the issue of unmet cross boundary housing needs. It is acknowledged within the Plan that there is a shortfall relating to the Greater Birmingham and Black Country HMA but the level beyond 2031 has yet to be established. It is considered that a study refresh is needed to take account of updated evidence and latest guidance. On this basis it is proposed that the Regulation 19 version of the plan will consider unmet housing need reviewing latest evidence and duty to cooperate discussions. SMBC would reiterate the importance of engaging in duty to cooperate discussions to ensure wider housing needs are met. The South Warwickshire Plan may need to address needs arising from both housing market areas. It is acknowledged that further evidence will be necessary to consider the wider housing market area through an update of the West Midlands Strategic Growth study which is currently underway.