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ID sylw: 107899

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Whilst Terra welcomes the SWA’s acknowledgement that the SWLP may need to play a role
in addressing the unmet housing need of neighbouring authorities within the Coventry &
Warwickshire Housing Market Area [C&WHMA]2 and Greater Birmingham and Black
Country Housing Market Area [GBBCHMA]3, Terra has some concerns regarding the
SWLP’s proposed approach.
2.59 The SWLP proposes – albeit not explicitly – to only assist with addressing the unmet
housing needs of the C&WHMA and GBBCHMA only when these unmet needs are defined,
and through the release of ‘reserve sites’. In this respect, the PO does not identify any
‘reserve sites’.
2.60 The NPPF emphasises that local planning authorities [LPAs] must cooperate to identify and
meet housing needs within their housing market areas [HMA] (Para 11b), and that plans
should be supported by relevant and up-to-date evidence (Para 32). It also reiterates that
LPAs’ continue to be under a Duty to Cooperate [DtC] (Para 24). It is also clear that:
“Plans come forward at different times, and there may be a degree of uncertainty about
the future direction of relevant development plans or the plans of infrastructure
providers. In such circumstances strategic policy-making authorities and Inspectors will
need to come to an informed decision on the basis of available information, rather than
waiting for a full set of evidence from other authorities.” (Para 28)
2.61 In this context, given the acuteness of the situation in these HMAs – outlined in detail
below – it will be necessary for the SWLP to make provision for any unmet housing needs
arising from these HMAs at the point of adoption, rather than deferring this matter to a
time when the unmet needs have been ‘evidenced’ and through the release of ‘reserve sites’.
Indeed, this is particularly pertinent, given the Inspector’s recent findings in respect of the
Solihull Local Plan Review where problems of Birmingham’s unmet need were not
adequately addressed within the plan, resulting in a terminal failure of the soundness of the
plan.
2.62 Given that the SWLP area sits within the two HMAs, both with serious historic housing
land supply challenges, Terra considers that based on the current evidence, that the SWLP
will need work with the adjoining LPA’s through this plan making stage to accommodate
some of these needs.
2.63 By way of example, whilst there is some degree of uncertainty regarding whether there will
be any unmet housing needs arising from the C&WHMA, it is plain to see that the SWLP
will need to assist in meeting the unmet housing needs of the GBBCHMA up to 2042 at the very least. Indeed, despite the revisions to the NPPF and SM alleviating pressures in the
GBBCHMA in part,4 a significant housing shortfall across the GBBCHMA remains, with an
estimated cumulative shortfall of c.42,900 homes across the WMCA up to 2042 under the
SM, arising from the Black Country Authorities [BCAs].5 To address these needs, the BCAs
are actively seeking to export these needs into the GBBCHMA – of which the SOADC falls
within – to be addressed through the forthcoming Local Plan.
2.64 At present, only Shropshire (1,500), South Staffordshire (640), Cannock Chase (500),
Stafford (2,000) and Telford & Wrekin (1,6806) are proposing to contribute towards
addressing these unmet housing needs. Collectively, this would equate to only 6,320
dwellings between 2018 and 2042, but, notably, several of these plans have stalled or are at
risk of being found unsound in due course. Notwithstanding the uncertainty regarding
these ‘contributions’, a significant unmet housing need would still remain within the
GBBCHMA. As such, at present, there is an unaccounted shortfall up to 2042, which is
substantial given the urban context of the BCAs, meaning that a significant proportion of
the unmet need will be deferred rather than dealt with, contrary to paragraph 35c of the
current NPPF. This highlights the importance of SWAs effectively delivering on their DtC.
2.65 Ultimately, there is a significant, and persistent level of unmet housing need across the
GBBCHMA and even with some Green Belt releases in the BCAs, it is unlikely to markedly
reduce the GBBCHMA’s significant shortfall of housing. To this end, the SWAs and wider
GBBCHMA authorities will need to make appropriate contributions towards addressing
these needs now. As such, whilst there remains some uncertainty regarding the exact
amount of unmet housing needs, under the revised NPPF, the SWLP will need to make
provisions based on the current level of information, rather than deferring until these
unmet needs are defined.
2.66 In terms of how much of these needs the SWAs should be addressing through the SWLP, it
is noted that there is not a single, or definitive, approach to determining the proportion of
unmet needs that any single Council should accommodate. That being said, the NPPF is
clear that Local Plans should be based on ‘proportionate evidence’ (Para 35c).
2.67 However, as the SWAs will be aware, Lichfields has historically provided an evidence-led
approach for how to distribute previous unmet housing needs sustainably. In particular,
Lichfields’ Black Country’s Next Top Model analysis considers the functional housing
market relationship between the various local authority areas in the GBBCHMA and the
origin-authorities of the unmet housing needs.
2.68 It should be noted that of the current contributions towards the BCA's unmet needs,
Wolverhampton has highlighted that the BCAs are attributing proportions based on
migration trends:
“is important to develop an evidence-led approach to dividing up such contributions
between authorities across the wider Greater Birmingham and Black Country Housing
Market Area (HMA) which have a housing shortfall. The proposed approach, which has
been agreed by the Black Country authorities, is to divide up contributions based on the
proportion of historic net migration flows between the contributing authority and
shortfall authorities.” (Para 4.6, Wolverhampton Local Plan - Regulation 19 Consultation
Cabinet Report 13th November 2024) (Emphasis Added)
2.69 Importantly, Lichfields’ approach (i.e. Functional Relationship) aligns broadly with the
BCA’s approach to apportioning proposed unmet need contributions to the BCAs as a
whole. Such an approach was also adopted by the approach taken in distributing Coventry’s
unmet needs across the C&WHMA previously. Again, the Inspector for the Stratford-on-
Avon Core Strategy (2017) endorsed this approach. More recently, in considering how the
unmet housing needs of Leicester could be addressed throughout the Leicester and
Leicestershire Housing Market Area [LLHMA], a similar functional relationship approach
was utilised and has been accepted by Inspectors at the Charnwood EiP.
2.70 Notably, Lichfields analysis takes account of the degree of migration and commuting
linkages within the GBBCHMA to the BCAs, opportunities to capitalise on sustainable
transport links and improve affordability, and the degree of environmental and physical
constraints which might impede on an authority’s ability to accommodate unmet housing
need. The analysis ultimately illustrates the functional linkages between the authorities
within the GBBCHMA, and the origins of the unmet housing need (i.e. the BCAs), and
shows how the BCA’s unmet housing needs could be sustainably distributed. For SOADC,
Lichfields’ functional housing market relationship analysis indicates that the SOADC
should be seeking to make provision for c.1% of the total unmet needs of the BCAs – or
around c.500 dwellings based on the current level of unmet need.
2.71 The above serves to highlight that there is evidence to suggest that the SWAs should be
seeking to make an appropriate contribution through the SWLP now, rather than deferring
it, in accordance with paragraph 35c of the NPPF. Terra considers that given the relatively
modest contribution required of SOADC when compared to the SWA’s own housing
requirement up to 2050, it would be entirely reasonable and sustainable for the SWLP to
make provision for this within the SWLP.
2.72 Terra considers that it is likely that there are sites throughout the SWLP area that could
sustainably contribute to addressing the SWA’s own housing needs and a proportion of the
GBBCHMA’s unmet housing needs. Indeed, it is evident that there are opportunities to
allocate ‘suitable, available and achievable’ land and sites in sustainable locations across
South Warwickshire. Indeed, Terra ’ site at SG14- East of Gaydon is just one of these
opportunities.