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ID sylw: 108271

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we support the recognition in Draft Policy Direction 4 that it may be necessary for the SWLP to help meet the unmet housing needs arising from the Coventry and Warwickshire HMA, and the Greater Birmingham and Black Country HMA, we are concerned with the lack of detail and the refences within the draft Policy.
The Policy Justification refers to the Coventry and Warwickshire HEDNA 2022 identifying the likely housing requirement for South Warwickshire and informing the unmet need arising from Coventry. The HEDNA is now out of date. Its housing requirements have been superseded by the new Standard Method in the NPPF December 2024. The Coventry and Warwickshire Authorities are required to prepare Plans using the revised Standard Method housing requirement and any unmet need against this requirement should be directed to another HMA authority.
It is also acknowledged that further work is required on the extent and distribution of the Greater Birmingham and Black Country HMA housing shortfall, especially given the age of the Strategic Growth Study, and the need to consider the revised Standard Method housing requirement.
It is appreciated that further work also needs to be done in respect of both the Coventry and Warwickshire, and Greater Birmingham and Black Country housing need shortfalls. However, there is currently no unmet housing need figure on which to comment. We are concerned that the first opportunity to comment on the unmet housing need figures for the Birmingham, Black Country and Coventry areas will be the Pre-Submission version of the SWLP. This may result in problems with the SWLP progressing towards the submission stage. Representations could be submitted regarding the extent of the shortfall that may result in the need to amend the SWLP housing requirement figure. It may be challenging for the Local Authorities to amend the Plan ahead of the submission without re-consultation.
It is, therefore, our view that in the lead up to the preparation of the Pre-Submission SWLP the Councils should identify the extent of the HMA’s housing shortfall they intend to plan for, and invite comments from interested parties.