Yes

ID sylw: 105765

Derbyniwyd: 07/03/2025

Ymatebydd: Wates Developments Ltd

Asiant : Savills

We support the draft policy direction and consider that if any arising unmet needs are declared by any authority within the Coventry and Warwickshire HMA or Birmingham and Black Country HMA prior to the publication of the Regulation 19 Publication SWLP, then the Councils should allocate land to support meeting these needs. We consider that the changes to the standard method for housing need calculation will also give rise to increased employment land requirements for many of the authorities within these HMAs and therefore there is a potential that the list of authorities who are unable to meet their own employment needs could grow in the coming months.

No

ID sylw: 105980

Derbyniwyd: 06/03/2025

Ymatebydd: Nick Chambers

The Opportunity Areas identified in WMSESS are primarily clustered in North Warwickshire and counties further north; whilst Areas 7 (Coventry & Rugby), 8 (M40/A46), and 9 (Redditch & Bromsgrove) are less favourable.

The lack of sustainable transport infrastructure between South Warwickshire and Birmingham/Coventry makes it completely unreasonable to argue that housing in South Warwickshire should meet the needs of Birmingham/Coventry.

These areas are closer to other county districts than to South Warwickshire, particularly when enabling road infrastructure is taken into consideration.

As stated on page 43, “Until there is greater certainty regarding the quantum of unmet needs from neighbouring housing market areas, it is premature to allocate reserve housing sites. The latest evidence and further discussions with neighbouring authorities will inform the Regulation 19 Submission policies on unmet housing need.”

Such housing demonstrably cannot be supported by local employment opportunities. Indeed, reference is made to Abbey Park in the Warwick District that “has faced deliverability challenges since consent and questions remains around the market attractiveness of the site in terms of its rural locations”. This observation is a clear market signal around the problems of creating employment opportunities in rural locations.

Other

ID sylw: 106191

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

I support the policy approach. Further work needs to be sone before submission of the SWLP.

The SWLP will need to satisfy the Duty to Co-operate as a legal requirement. However, in recent years the strategic element of planning for housing has almost disappeared. No reliable assessment of housing shortfall in the West Midlands Conurbation has been carried out since the 2018 West Midlands Study. Shortfalls in housing delivery amongst Birmingham and the Black Country authorities have worsened over the past few years but they have not produced evidence to support their requests for assistance. The new Government is committed to introducing a new strategic planning system, but in the meantime, LPA’s will need to implement the Duty to Co-operate and further work will need to be done before the submission of the SWLP.

Other

ID sylw: 106216

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala broadly agrees with the approach in Draft Policy Direction 4 and welcomes the statement in Paragraph 4.4 with regards to the Duty to Cooperate. However, the Local Plan should make reference to a realistic level of need based on discussions and evidence to date with neighbouring authorities. The evidence base should be updated to account for expected changes from the latest standard method calculation which will significantly increasing housing needs. The recent withdrawal of the Solihull Local Plan Review following the Inspector's findings of a significant deficit in housing land supply made reference to not only meeting Solihull's own local need in full but also to contribute approximately 2,000 homes to unmet need arising from Birmingham by 2030/31. This highlights that this issue is an important consideration for the South Warwickshire Local Plan.

No

ID sylw: 106343

Derbyniwyd: 27/02/2025

Ymatebydd: Neil Francis

Your consultation states that, for the Greater Birmingham and Black Country HMA, there is evidence of a significant shortfall between housing requirements and land supply. However, the overall scale of the shortfall has not been collectively quantified beyond 2031 since the GBBCHMA Strategic Growth Study (2018). A study refresh is required to re-evaluate the housing shortfall considering more recent evidence and policy. Council officers meet regularly with counterparts from other Councils and with various stakeholders in both the Coventry & Warwickshire and Greater Birmingham & Black Country Housing Market Area to discuss cross boundary issues. Until there is greater certainty regarding the quantum of unmet needs from neighbouring housing market areas, it is premature to allocate reserve housing sites.
Your consultation is not clear on this position. Whilst you do not specifically say that site SG24 is identified to meet the needs of housing in Birmingham under the duty to cooperate, the URL on the interactive map takes the user directly to this section of the consultation which suggests this may be a consideration. Under the new NPPF, the housing figures for Birmingham have reduced from 7,174 to 4,448. Whilst Solihull was previously showing the provision of 2,000 houses to meet the needs of Birmingham under the duty to co-operate, there is no evidence to suggest that will now be the case, especially given the reduced number for Birmingham.
It is also clear from your consultation that the overall scale of any shortfall has not been collectively quantified beyond 2031 since the GBBCHMA Strategic Growth Study (2018). You also indicate that a study refresh is required to re-evaluate the housing shortfall considering more recent evidence and policy. Until there is a greater certainty regarding the quantum of unmet needs from neighbouring housing market areas it is premature to allocate reserve housing sites.
In addition, I would also note that there are public walkways over the proposed sites which could potentially constrain their development.

Yes

ID sylw: 106365

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium (WMHAPC)

Asiant : Tetlow King Planning

Policy Direction 4 - Accommodating Housing Needs Arising from Outside South Warwickshire Appeal decision 3319752 states that Warwickshire District Council’ can demonstrate 7.12 years of supply against the Standard Method; Stratford-on-Avon’s latest Five-year housing land supply statement states that at 1 April 2024, they can demonstrate 24.65 years of supply. Both respective
authorities exceed the five year housing land supply requirement significantly and when combined, is a
healthy sum for the SW area.
The WMHAPC is pleased to see that the SW authorities are taking a collaborative approach with neighbouring authorities to ensure affordable housing needs are met, sharing responsibilities amongst the authorities of Coventry, Warwickshire, Greater Birmingham and Black Country, all of whom are known to have a constrained housing market area with significant shortfalls in housing provision.
The draft Policy Direction 4 states that: “housing or employment need that cannot be met within the
administrative boundaries of the authority in which the need arises and part or all of the need could most appropriately be met within the South Warwickshire Local Plan, reserve sites will be released for this purpose, or when the relevant authority’s 5 year housing land supply calculation falls below the thresholds set out in national planning policy guidance.” The WMHAPC welcomes this approach although seeks further clarity on the monitoring and strategy to enforce the release of “reserve sites”.

Other

ID sylw: 106507

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

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.
The latest Housing and Economic Development Needs Assessment (HEDNA) for Coventry and Warwickshire
(C&W) underscores the urgent need for a regional approach to addressing unmet housing demand. With an
annual housing requirement of 4,906 dwellings per annum (dpa) and a substantial shortfall in affordable
housing—3,833 rented affordable homes annually—Coventry faces the most significant pressure within the
sub-region. Given that 96% of Coventry’s affordable housing need remains unmet, it is imperative that South
Warwickshire plays an active role in accommodating this demand. Previous commitments, such as the
Memorandum of Understanding (MoU) between Coventry and Warwickshire authorities, have resulted in
Stratford-on-Avon and North Warwickshire allocating 2,880 dwellings to assist Coventry. However, these
allocations must be revisited within the South Warwickshire Local Plan (SWLP) to ensure a continued and
strategic approach to housing provision that aligns with the latest evidence base.
The SWLP must also recognise its strategic position within both the Coventry and Warwickshire Housing
Market Area (HMA) and the Greater Birmingham and Black Country HMA. Stratford-on-Avon has historically
contributed to both HMAs, with allocations of 2,720 dwellings for Greater Birmingham and Black Country
and 2,880 dwellings for Coventry and Warwickshire. As the plan extends to 2050, it must acknowledge the
ongoing cross-boundary pressures and proactively accommodate a proportionate share of the unmet
housing need. Deferring this responsibility to development management decisions or reserve sites would
undermine the plan-led approach required by the National Planning Policy Framework (NPPF). Instead, a
forward-looking policy framework should be established, ensuring that housing allocations
comprehensively address regional demands while balancing infrastructure capacity and sustainability
objectives.
Additionally, the SWLP must integrate a robust duty-to-cooperate mechanism, reflecting the demographic,
economic, and migration trends influencing South Warwickshire’s housing market. By proactively planning
for these needs now, the SWLP can provide certainty for local authorities, developers, and communities,
ensuring that housing growth aligns with economic and social sustainability. A clear strategy for
accommodating unmet housing need must be embedded within the plan to avoid the risks associated with
reactive policymaking, uncoordinated site releases, and an insufficient five-year housing land supply.

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. It is
imperative that this 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 or main modifications.

Yes

ID sylw: 106620

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

We fully support the need for the SWLP to contribute to meeting unmet housing need from neighbouring authorities. In our view, sustainable sites in the north west of the SWLP area, including the Site to the south of Henley-in-Arden, are likely to be very well placed to respond to such need, particularly where those sites are located in close proximity to key transport nodes.

Yes

ID sylw: 106641

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

While it is acknowledged that further work is required on the extent and distribution of the Greater Birmingham and Black Country HMA housing shortfall, and that further work also needs to be done in respect of Coventry housing need shortfalls, there is currently no unmet housing need figure on which to comment. We are therefore concerned that the first opportunity to comment on the unmet housing need figures for these areas will be the Pre-Submission version of the SWLP. Consequently there is a real risk of the SWLP’s progress towards the Submission stage being delayed whilst the extent of the housing shortfall is fully understood and the need for any amend to the SWLP housing requirement figure is addressed following 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.

Yes

ID sylw: 106799

Derbyniwyd: 07/03/2025

Ymatebydd: H W Smith Ltd

Asiant : Bruton Knowles

The Councils must comply with their legal duty to cooperate and assist in meeting unmet needs where possible, and this should be addressed prior to the SWLP reaching the Regulation 19 stage. In considering contributions to unmet needs, it should be recognised that Site E1, in combination with the Site, would provide a significant contribution towards meeting South Warwickshire’s own housing needs and unmet needs.

No

ID sylw: 106961

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The Policy states that the SWLP will be underpinned by housing need and availability evidence base. As stated in our response to Policy Direction 1, the HEDNA is required to be updated to reflect the updated Standard Method and the implications that this may have on the Coventry and Warwickshire Housing Market Area (‘HMA’) and the Greater Birmingham and Black Country HMA. The majority of authorities within the HMAs are seeing an increase in their minimum housing need.
The NPPF is clear that the housing needs of neighbouring authorities should be met over the plan period (paragraphs 11 and 69). In order to be positively prepared (NPPF paragraph 36), the SWLP should make a contribution to the both HMA shortfalls.

Other

ID sylw: 107011

Derbyniwyd: 07/03/2025

Ymatebydd: Cherwell District Council

DTC RESPONSE:

We note that in paragraph 4.4 and Draft Policy Direction 4 that South Warwickshire Local Plan
references that there may be a need to look at accommodate ‘unmet need’ from the Coventry and
Warwickshire Housing Market Area and the Greater Birmingham and Black Country Housing Market
Area. We would like to be kept up to date on these discussions and any future proposals through
our future Duty to Cooperate discussions and in relation to any proposals that are put forward that
may impact Cherwell District.

Cross Boundary
It maybe useful to include a diagram which shows the relationship to the adjacent local authorities
including Cherwell, Oxfordshire County Council etc which also visually highlights the above points
along with a section of text.

No

ID sylw: 107035

Derbyniwyd: 21/02/2025

Ymatebydd: Coventry and Warwickshire Chamber of Commerce

The CWCCC is concerned by the whole approach in the emerging plans and proposals related to the Duty to Cooperate.
The first point to note is that the draft Policy direction here deals only with housing provision. The wording must be amended to recognise employment provision. The recently published Regulation 19 consultation regarding Coventry City sets out explicit provisions to “export” employment provision to surrounding/neighbouring local
authority areas which includes this plan area. The draft strategy is currently silent on this matter. This is surprising given the statements elsewhere (ref Para 1.10 )suggesting
the close liaison and “ active engagement “between the sub regions local authorities.

This Regulation 18 draft plan is silent on this specific issue related to employment provision and the DTC. If there has been effective liaison and partnership, then it would be reasonable to expect that it should be reflected in this draft Policy Direction.

Yes

ID sylw: 107062

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

Duty to Cooperate

Warwick District Council and Stratford District Council have worked collaboratively with NBBC regarding cross-boundary strategic issues, alongside adjoining and nearby local authorities within the Coventry and Warwickshire Housing Market Area. Effective and on-going joint working has and will continue to be undertaken as the Council’s respective Local Plans are progressed through the plan-making system.

NBBC agrees that it is yet to be established to what extent there will be any unmet need, or of what type (e.g. housing and/or employment), from elsewhere within the Coventry and Warwickshire HMA. The Borough Plan Review (2021-2039) is progressing towards Main Modifications consultation following the conclusion of the Examination in Public hearing sessions. NBBC can confirm that there is no unmet housing or employment need from Nuneaton and Bedworth Borough. NBBC would welcome the opportunity to discuss a Statement of Common Ground with the South Warwickshire authorities.

Other

ID sylw: 107069

Derbyniwyd: 16/01/2025

Ymatebydd: Walsall Council

Strategic cross boundary issue 1: Housing

Walsall responded to the SWLP scoping consultation as part of the Association of Black Country Authorities (ABCA). This response stated that evidence prepared for the Black Country Plan (BCP) indicated the Black Country could not accommodate all its needs in the urban area. Historically the functional relationship between the Black Country and South Warwickshire is limited. However, housing land capacity constraints in the Black Country will create a ripple effect across the conurbation and wider housing market area. We continue to seek assistance from other districts.

The BCP is no longer proceeding, and the Black Country authorities are preparing individual local plans. However, evidence of housing need and supply remains. Furthermore, the December 2024 NPPF introduces a new standard method that substantially increases housing need for the majority of local authorities. Walsall’s increase is from 906 to 1,148 homes annually. Walsall is constrained by Green Belt and we estimate our current housing supply shortfall not including Green Belt is approximately 15,000 homes over the period 2024-2042. We will therefore need to continue to work with authorities from across the wider housing market area to meet our needs, including authorities with land beyond the Green Belt in accordance with the sequential approach set out in NPPF paragraph 147.

Strategic cross boundary issue 2: Employment

The Black Country Economic Development Needs Assessment (EDNA) has been updated (November 2024) to inform individual Black Country local authority plans. This confirmed need for employment land remains similar to in 2021. There remains a shortfall of supply within the Black Country, however contributions to meet this shortfall have been confirmed in local plans from immediate neighbours that are either at examination or have been submitted for examination.

We still support the view from the ABCA response to the Scoping consultation that there should be a balance between new homes and employment land in South Warwickshire to ensure homes are provided close to people’s places of work. However, employment is not an issue where the relationship with Walsall or the rest of the Black Country requires explicit consideration in the SWLP.

Yes

ID sylw: 107192

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

Draft Policy Direction 4 explains that the housing need and availability evidence base for the SWLP
will consider the Coventry and Warwickshire Housing Market Area and the Greater Birmingham and
Black Country Housing Market Area (GBBCHMA). Sandwell supports the proactive approach of the Policy Direction to seek to meet relevant unmet housing needs arising from the Housing Market Areas.

The consultation document states that sufficient options and flexibility have been identified to meet more than South Warwickshire’s own need and acknowledges that there may be unmet need from elsewhere, but correctly states that this has yet to be quantified. Since publication of this document a refresh of the GBBCHMA Strategic Growth Study has been commissioned, the first phase of this will estimate the housing shortfall against the new 2024 LHN baseline. The early signs, however, are that the conurbation will struggle in terms of capacity and delivery to meet its 2024 LHN, albeit the focus of the challenge may have shifted from Birmingham to Solihull and the Black Country.

The offer to assist with meeting some of this shortfall, therefore, is welcomed. Any additional growth proposals, however, will need to be mindful of the recommendations of the New Towns Task Force and any decisions on how to progress with these.

Yes

ID sylw: 107201

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

We fully support the need for the SWLP to contribute to meeting unmet housing need from neighbouring authorities. In our view, sustainable sites, including the site off Station Road, Bishops Itchington, are likely to be very well placed to respond to such need, particularly where those sites are located in close proximity to key transport nodes.

Yes

ID sylw: 107213

Derbyniwyd: 06/03/2025

Ymatebydd: Catesby Estates

Asiant : Mr Will Whitelock

We support the recognition that there may be a need to look to accommodate ‘unmet need’ from the Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA. South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city.
However, there is no detail to comment on at this stage. The pre-amble to Draft Policy Direction 4 - Accommodating Growth Needs Arising from Outside South Warwickshire states: ‘It is yet to be established to what extent and what uses (e.g. housing and/or employment) there will be any unmet need from elsewhere within these housing market areas [Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA]. Some of this need will be met by other constituent Local Planning Authorities within both HMA’s; however, through Duty to Co-operate discussions; the Councils will commit to continually consider this need and work with those authorities on how this can be achieved.’
A number of West Midlands authorities have seen a significant increase in their Local Housing Need figure under the new Standard Method (save for Birmingham, Sandwell and Coventry). The West Midlands would be expected to deliver 29,940 dwellings per annum, a 21% increase compared to the previous method.
There will undoubtedly be challenges for neighbouring authorities to meet their own needs and hence the South Warwickshire authorities may well need to increase their housing need figure by reason of the requirement to accommodate any unmet needs.

Yes

ID sylw: 107225

Derbyniwyd: 05/03/2025

Ymatebydd: Andrew Sweeney

Asiant : Mrs Eleanor Lovett

It is positive that the emerging Plan recognises that there may be a need for the Plan to address housing or employment needs that cannot be met within the administrative boundaries of authority in which the need arises. This represents a key part of the tests of soundness, as in order for a Plan to be ‘effective’, it must be based on effective joint working on cross-boundary strategy matters, and dealt with proactively rather than deferred.
it is important to quantify the level of unmet need arising from adjacent authorities at the earliest opportunity, to ensure that the Plan is predicated on meeting an appropriate minimum level of housing. This should equally inform the spatial strategy, ensuring that where cross-boundary needs are required to be addressed by the Plan, these should be met within areas that are well-linked and in close proximity geographically to where the need arises from. It is considered that the site at Springbrook Lane performs well in this regard when considering needs arising from the Greater Birmingham and Black Country housing market area, as it is situated within the north-western edge of the Plan area, and well located by road and rail to the Birmingham and Solihull urban area.

No

ID sylw: 107250

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

The policy direction is not consistent with the intentions of the NPPF 2024, notably paragraphs 11(b), 27 and 28. The new paragraph 27 provides that plans should ensure that unmet needs from neighbouring areas are accommodated where it is practical to do so. Moreover, the changes to paragraph 28 acknowledge that plans come forward at different times, and that there may be a degree of uncertainty about the future direction that there is a 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.
There is a need to fully understand the growth strategy, how this meets the housing requirement as per the Standard Method, including any unmet need. Moreover, how a 5-year HLS will be maintained.

No

ID sylw: 107261

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

The CNL should not be expected to accommodate these growth needs.

The Board acknowledges that it is appropriate for the South Warwickshire Councils to give consideration to accommodating unmet needs arising from outside South Warwickshire. However, the approach taken by Draft Policy Direction 4 is, in the Board’s opinion, too permissive.
Paragraph 36 of the National Planning Policy Framework (NPPF) states, inter alia, that:
•
Plans are ‘sound’ if they are:
a)
Positively prepared … informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.10 (N.B. Added for emphasis).
We recommend that the underlined text should be reflected in Draft Policy Direction 4. In other words, the South Warwickshire Councils should only give consideration to accommodating unmet needs arising from outside South Warwickshire if it is practical to do so and if it is consistent with achieving sustainable development. This should include consideration of paragraphs 11b and 11d of the NPPF, which set out the circumstances in which objectively assessed needs (OAN) do not have to be met in full.
The Government’s Planning Practice Guidance on the Natural Environment states that National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from neighbouring (non-designated) areas’.11 Policy CE15 of the CNL Management Plan expands on this by stating that ‘in the context of the CNL, this includes unmet needs relating to adjacent urban areas and unmet needs arising in local authority areas that do not overlap with the CNL’.12 In this context, it would not be appropriate to release reserve sites in the CNL on the basis of accommodating unmet needs from neighbouring local authority areas. This should be made explicit in Draft Policy Direction 4.

Other

ID sylw: 107402

Derbyniwyd: 05/03/2025

Ymatebydd: Oxhill Parish Council

The document identifies that suitable brown field site should be used before looking at green field sites. We would like to ensure that all brown field sites have been considered in the areas where there is a shortfall before considering moving that excess to South Warwickshire and that the proposed identified need is a true representation of the actual need. Building in areas away from these conurbations (e.g. Birmingham, Coventry) will yet again increase congestion on already very busy roads as people travel to work, again moving away from a net zero and climate resilient South Warwickshire. This will also put a strain on already over used services e.g. Warwick hospital, shopping centres, other health services and schools.

Other

ID sylw: 107493

Derbyniwyd: 07/03/2025

Ymatebydd: Suzanne Ross

Asiant : Savills

We strongly support the Local Plan’s intention to consider the Coventry and Warwickshire Housing Market Area as well as the Greater Birmingham and Black Country Housing Market Area (HMA) with meaningful engagement between the authorities within the HMA. It is clear that the NPPF expects housing needs to be met in full and cross boundary working is a tool to achieve this. Coventry and Warwick, which are already significantly constrained including by Green Belt land, will struggle to meet their housing needs and South Warwickshire is a logical area to accommodate at least some of this unmet
given the proximity and existing transport connections.
Whilst we do not necessarily expect our client’s land to be suitable for meeting the unmet needs of any town or city, any additional land that is needed for this purpose, will have a knock-on effect of increasing the number of additional sites subsequently needed to meet the districts own needs.
Small and medium scale sites such as our clients land at Alcester Road, Stratford-upon-Avon (HELAA Site Ref 492 and 827) have an important role to play in ensuring a strong supply of deliverable sites across the Plan period.

Yes

ID sylw: 107509

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

Previous commitments, such as theMemorandum of Understanding (MoU) between Coventry and Warwickshire authorities, have resulted in Stratford-on-Avon and North Warwickshire allocating 2,880 dwellings to assist Coventry. However, these allocations must be revisited within the South Warwickshire Local Plan (SWLP) to ensure a continued and strategic approach to housing provision that aligns with the latest evidence base.
The SWLP must also recognise its strategic position within both the Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA. Stratford-on-Avon has historically contributed to both HMAs, with allocations of 2,720 dwellings for Greater Birmingham and Black Country and 2,880 dwellings for Coventry and Warwickshire. As the plan extends to 2050, it must acknowledge the ongoing cross-boundary pressures and proactively accommodate a proportionate share of the unmet housing need. Deferring this responsibility to development management decisions or reserve sites would undermine the plan-led approach required by the National Planning Policy Framework (NPPF). Instead, a forward-looking policy framework should be established, ensuring that housing allocations comprehensively address regional demands while balancing infrastructure capacity and sustainability objectives.
Additionally, the SWLP must integrate a robust duty-to-cooperate mechanism, reflecting the demographic, economic, and migration trends influencing South Warwickshire’s housing market.
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. It is imperative that this is planned for now, having regard to NPPF paragraph 69.

Yes

ID sylw: 107582

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

Coventry City Council supports and welcomes the principles behind Draft Policy Direction
4, which states:

"The South Warwickshire Local Plan 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. This evidence base will consider a strategic approach that addresses any
shortfall of land availability to deliver in full the Housing Market Area's Objectively
Assessed Housing Need or other evidenced housing need arising outside South
Warwickshire.
If evidence and the duty to co-operate process clearly indicates that there is a
housing or employment need that cannot be met within the administrative boundaries
of the authority in which the need arises and part or all of the need could most
appropriately be met within the South Warwickshire Local Plan, reserve sites will be
released for this purpose, or when the relevant authority's 5 year housing land supply
calculation falls below the thresholds set out in national planning policy guidance."

As set out earlier in these representations, Coventry City Council works closely with
partners across the Housing Market Area (HMA) and the Functional Economic Market Area
(FEMA), and this includes regular meetings and discussions under the Duty to Co-operate.
Coventry has reached the Regulation 19 stage of plan making and as partners are aware
intends to accommodate its own identified housing need, however this does need to be
tested through examination.

It is also requested that the policy is amended to include clarification that the
accommodation of any shortfall arising from neighbouring authorities should be located
within the geographical housing market area from which that shortfall arises and that its
should be made clear which sites are selected for such purpose.

As the two councils producing the SWLP will be aware, Coventry City Council considers
that it has a shortfall of 45 hectares for local employment need and is seeking help from
partners across the FEMA in addressing this, along with addressing the wider issue of
strategic employment. Discussions are ongoing across the FEMA and Coventry welcomes
acknowledgement of this through the SWLP Preferred Options and further discussions
would be welcomed.

Other

ID sylw: 107598

Derbyniwyd: 07/03/2025

Ymatebydd: National Highways

We welcome the Council’s commitment to engaging with the duty to co-operate with
neighbouring housing market areas (HMAs) including Coventry and Warwickshire
HMA and the Greater Birmingham and Black Country HMA to accommodate ‘unmet
need’ as required. We note that it is yet to be established to what extent and what
uses (eg. housing and/or employment) there may be for South Warwickshire to accommodate and we would welcome further detail on this (along with a supporting
evidence base) as and when any unmet need is defined.

Yes

ID sylw: 107663

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala broadly agrees with the approach laid out by Draft Policy Direction 4 but notes the importance of the duty to co-operate and the need to ensure that growth needs are accurately calculated. Cala welcomes the acknowledgement at Para 4.4 that states, “Under the Duty to Co-operate, the Council is obliged to engage proactively with certain prescribed bodies to address strategic cross boundary issues. There may be a need to look to accommodate 'unmet need' from the Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA” but re-asserts its comments in relation to section 3, para 3.1 of the SWLP preferred options that consideration of unmet need should start to take place in the early stages of the plan-making process and the unmet need position should continue to be reviewed under duty-to-cooperate obligations. It is therefore suggested that the Local Plan should aim to make reference to a realistic level of need predicated on discussions and evidence to date with its neighbouring authorities.
The clear increase in the housing requirement arising from this new method of calculation is an important consideration for the South Warwickshire Local Plan, especially in light of recent Inspector’s findings on the Solihull Local Plan Review which concluded (September 2024) that there was a significant deficit in housing land supply which needed to be addressed through its current Local Plan Review and not through a future review.

No

ID sylw: 107736

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The Policy states that the SWLP will be underpinned by housing need and availability evidence base. As stated in our response to Policy Direction 1, the HEDNA is required to be updated to reflect the updated Standard Method and the implications that this may have on the Coventry and Warwickshire Housing Market Area (‘HMA’) and the Greater Birmingham and Black Country HMA. The majority of authorities within the HMAs are seeing an increase in their minimum housing need.
The NPPF is clear that the housing needs of neighbouring authorities should be met over the plan period (paragraphs 11 and 69). In order to be positively prepared (NPPF paragraph 36), the SWLP should make a contribution to the both HMA shortfalls.

No

ID sylw: 107812

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The evidence on shortfalls in the HMAs is out-of-date and should be refreshed as a matter of priority. To deliver the housing the HMAs require will necessitate a clear delineation of responsibility under the duty to cooperate to address any shortfalls, including through the SWLP Part 1.

In anticipation of significant shortfalls and in the context of significant increases for many authorities under the Standard Method, the Councils should plan appropriately and identify reserve sites for this purpose in order for the plan to be sound.

Other

ID sylw: 107828

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Andrew Martin

As well as favouring other sites such as BW, I believe that we should question whether it is really appropriate for Stratford-upon-Avon at this (or any future) time to take more than its fair share of expansion, especially by not taking an unfair load from other towns. I understand that Stratford already has a rolling housing land supply of over 20 years!