BASE HEADER

Other

ID sylw: 108293

Derbyniwyd: 05/03/2025

Ymatebydd: Bostrom Property LLP

Asiant : Fisher German

The Council’s proposed approach is to meet the provisions of the 2024 NPPF through a flexibility
allowance (2,188 dwellings per annum), but the Plan seems to adopt a lower housing requirement
of only 1,679 dwellings per annum, which is derived from the HEDNA (November 2022) (which is
already out of date having regard for the PPG which allows a 2-year period). For the avoidance of
doubt, given the Plan has almost certainly missed the transitional arrangements which would
allow the above approach to be advanced, the housing requirement must at the very minimum be
the Local Housing Need figure of 2,188 dwellings per annum. It is not appropriate or in compliance
with the NPPF 2024 to cover off Local Housing Need through supply but not the adopted housing
requirement, unless the Council is advancing an exceptional circumstances argument.
2.2 Paragraph 11 of the NPPF (2024) affirms “strategic policies should, as a minimum, provide for
objectively assessed needs for housing”. Paragraph 69 states 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 that cannot be met within neighbouring areas) can be met over
the plan period. The requirement may be higher than the identified housing need if, for example, it
includes provision for neighbouring areas, or reflects growth ambitions linked to economic development
or infrastructure investment”.
2.3 It is not sound to identify a housing requirement below Local Housing Need (without an
exceptional circumstances argument), justified through having sufficient supply to meet Local
Housing Need. If there is sufficient supply to meet the housing requirement, it is considered highly
unlikely exceptional circumstances could exist which would justify an alternative approach,
particularly having regard to historic delivery rates (discussed below) and the impetus on uplifting
housing delivery endorsed by the most recent framework.
2.4 The housing requirement must therefore be clear it is a minimum of 2,188 dwellings per annum,
or 54,700 dwellings over the Plan period derived from the Standard Method, not the now out of
date requirements derived from the HEDNA. This is required as a matter of soundness, not least
5
‘Positively prepared’, which the NPPF prescribes as “providing a strategy which, as a minimum, seeks
to meet the area’s objectively assessed needs”; but also consistent with national policy having regard
for paragraphs 11 and 69 as provided above.
2.5 However, in accordance with the NPPF and PPG, it is necessary to consider whether the housing
requirement should be Local Housing Need, or a figure in excess of Local Housing Need. This uplift
can be derived for numerous factors, including seeking to increase economic growth, affordable
housing delivery, or relating to opportunities arising through the delivery of strategic infrastructure.
The Iceni Paper ‘Advice on Housing & Employment Land Needs’ (February 2024) affirms that that
2,808 dpa may be required in South Warwickshire utilising a 5-year migration scenario, and Table
6.10 indicates that at least 2,772 dpa is needed to meet the total affordable housing need. The
Council’s own evidence is clear that if there is to be movement from Local Housing Need, it is likely
to be higher, not lower as currently proposed.
2.6 The PPG also advised logically that evidence of higher levels of delivery in previous years can be a
strong sign of market need and this should be considered as part of setting the housing
requirement. It is noted having regard for the Council’s monitoring papers that the Plan area has
exceeded the Local Housing Need figure of 2,188 dwellings per annum 6 out of 8 years, including
2016/17, 2017/18, 2018/19, 2019/20, 2021/22 and 2022/23. It is noted the only year since
2015/16 where housing delivered was below 2,188 dwellings per annum was 2020/21, peak covid
years and thus clearly could have been impacted by Covid restrictions. In two years the Council
delivered in excess of 2,600 dwellings per annum. These figures strongly suggest that the housing
requirement should be increased, not decreased, from Local Housing Need and the Council’s
approach is likely to stifle what is a healthy and successful housing market. This squeezing of new
supply could expedite house price growth, disproportionate to wage growth, and could thus result
in lower spending in the local economy and less opportunity for younger people, or those without
existing equity, to stay in the area.
2.7 Another crucially important factor to review is a consideration of unmet need, but this is subject
of its own question answered below.
2.8 It is noted that the plan assumes windfall delivery of 9,375 dwellings over the Plan period. This
equates to circa 20% of the supply proposed. For such high amount of windfall to be assumed, the
Council needs strong evidence both on historic delivery, but also in respect of ongoing supply. In
6
respect of historic delivery, regard would need to be had for fluctuating delivery rates. It is noted
that the AMR (2022/23) indicates windfall delivery varies significantly from almost a thousand
dwellings achieved in some years, to below 50 dwellings in others.
2.9 Windfall redevelopment opportunities are ultimately a finite resource and those sites which are
easiest and most appropriate for development will likely have been developed, leaving a pool of
more difficult sites less likely to be delivered. Whilst there will be a churn in the supply as sites
become available, recent years delivery cannot be guaranteed to be sustainable over a long period..
Whilst windfall allowance rates by definition cannot be wholly predicted, clearly the higher the
reliance on the windfall delivery, the higher the risk of plan failure is if sites do not to come forward.
The windfall rate should be reduced to reflect this historic uncertainty in respect of delivery.
2.10 It is noted that the approach adopted by the Council is that that LHN will be met through essentially
additional supply or buffer. Notwithstanding our comments above in relation to the soundness of
this approach, it is further worthy to note that when the Council adopts LHN or higher as its
housing requirement, it will be necessary still for the Plan to contain a buffer to ensure delivery. In
accordance with the NPPF, this should be in excess of 5%, but for contingency should be closer to
20%.
2.11 In terms of spatial strategy, the Council confirmed that it intends to proceed with a ‘Sustainable
Travel and Economy’ spatial growth strategy, with three ‘priority areas’ for growth identified.
Priority 1 is brownfield land. Whilst the Council concede brownfield land cannot meet all of its
development requirements, the strategy shows a clear preference for brownfield land and as such
the Council should receive positively additional brownfield opportunities such as those associated
with the Arrow Works site.
2.12 It is noted that the Arrow Works site is not a designated employment site and is located in the
highly sustainable settlement of Studley (currently designated as a Main Rural Centre in the
adopted Core Strategy), close to neighbouring Redditch. The site is in close proximity to existing
bus stops on Redditch Road, with further higher frequency services available a short walk away
on Alcester Road. The Alcester Road forms the settlements main street with various services and
facilities in close proximity of the site including doctors, schools, shops, etc. The site is highly
sustainable and suitable for residential development and should be considered positively as part
7
of ongoing site appraisal and allocation work ahead of the next phase of consultation.
2.13 The site’s tenants have not requested a further extension in lease and thus the current use is
anticipated to cease in 2026. We understand the current tenant have been receiving abatement
notices from the council regarding opposition to the noise levels associated with the current
commercial use. As such, the landowners do not see a sustainable future commercial use of the
site, hence their confidence in residential. The Council should thus recognise this opportunity to
end a noise generating use which is causing amenity issues whilst allocating a site which is
predominantly brownfield.
2.14 A call for sites form has been provided. It is noted that this site falls outside of the scope of the
current Call for Sites consultation, but given the site’s context and opportunity, we hope the Council
will take a flexible approach with regards to this submission.