BASE HEADER

Yes

ID sylw: 108163

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support that the SWLP will be underpinned by a housing need and availability evidence base that considers the Coventry and Warwickshire Housing Market Area as well as the Greater Birmingham and Black Country Housing Market Area.
Whilst there is evidence that there is a significant shortfall between housing requirements and supply within the Greater Birmingham and Black Country HMA, the overall scale has not been collectively quantified beyond 2031 since the GBBCHMA Strategic Growth Study 2018. The Coventry and Warwickshire Housing and Economic development Needs (HEDNA) 2022 states that Stratford-on Avon will need to consider the unmet needs from Birmingham in setting housing targets, but this figure is not quantified. It appears also that the unmet needs figures from Coventry are also not yet known. It is clear therefore that a refresh of the Strategic Growth Study is required as well as further discussions with Coventry to discuss the cross-boundary issues.
On this basis the clear indication now is that the SWLP will need to make a contribution by way of a duty to co-operate and accommodate unmet housing needs arising from outside the SWLP plan area. The policy justification states that the policies on unmet housing need will be dealt with at Reg 19 Submission stage through consideration of the draft reserve housing allocations within the Stratford-on-Avon District Council’s Site Allocation Plan. This approach is not supported, It is imperative that this unmet need is planned for now, having regard to NPPF paragraph 69. It is not appropriate to defer the duty to co operate to reserve sites – which infers that a commitment to the duty to co-operate will be deferred by stealth. The approach to deferring the duty to co-operate to the development management function as a result of a deficiency against the 5 year housing land supply position is worse still. The planning system is plan led, and the plan led system should accommodate all of the housing needs arising from both within the plan area and within the wider HMA’s. To do otherwise would be a serious failing of the SWLP, a matter which would go to the heart of the plan and not able to be rectified through any examination process/main modifications.