Yes

ID sylw: 107843

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey strongly support the need for the Draft Plan to respond positively to the identification of unmet housing need arising from the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) and Coventry and Warwickshire Housing Market Area (CWHMA).
Across the GBBCHMA the current standard method suggests a need for approaching 16,000 homes per annum, whilst the need across the CWHMA has slightly decreased to 5,295 (102 lower than the previous standard method). The need for the GBBCHMA is notably higher than that concluded in the 2018 Strategic Growth Study, which suggested a need between circa 10,200 and 12,400 homes per annum. This is a substantive increase, whilst recognising the latter range projected needs only to 2031, and demonstrates the importance of the Plan responding positively to ensuring that needs across the HMA are accommodated over the course of this Plan period. Although Warwick is outside the GBBCHMA, Stratford is within the HMA and as such, this should be taken in to consideration. There continues a need for any shortfalls arising from the GBBCHMA and CWHMA to be considered within the SWLP.
Taylor Wimpey supports the approach set out in Draft Policy Direction 4 to work with the HMA authorities, this accords with the NPPF Duty to Cooperate (Paragraph 24).
Given the scale of the need and the failure for authorities across the HMA to provide for this need in the current generation of Local Plans, there is an imperative on joint working to positively respond. The Council must ensure that the Draft Plan adopts a sufficiently positive and flexible approach to ensure that a proportionate contribution to addressing unmet needs which are identified through discussions and the publication of joint evidence.

Other

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.

Yes

ID sylw: 107920

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Under the Duty to Co-operate, the Council is obliged to engage proactively with neighbouring authorities to address strategic cross boundary issues. This includes a potential need to accommodate ‘unmet need’ from the Coventry and Warwickshire Housing Market Area (HMA)
and the Greater Birmingham and Black Country HMA. While both Stratford and Warwick districts are located within the Coventry and Warwickshire HMA, only Stratford lies within the Greater Birmingham and Black Country HMA.
The most recent GBBCHMA Position Statement Addendum was published in April 2023, reporting a total shortfall of some 106,654 dwellings with total contributions of only 18,181 dwellings committed. These figures are now out-of-date on account of Local Plan progress and revisions to the calculation of Local Housing Need derived from the Standard Method. However, it is understood that work is underway to update the Position Statement to 2025, and we still expect this work to still identify a significant deficit in supply across the GBBCHMA. This shortfall should be taken into account in the preparation of the South Warwickshire Local Plan.
Draft Policy Direction 4 sets out, the Councils will commit to “continually consider this need and work with those authorities on how this can be achieved.”
In this regard, Draft Policy Direction 4 suggests that 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.
Whilst this is commendable in theory, it is not understood how the Councils intend to allocate reserves sites through the SWLP when the scale or type of development need has not yet been determined. For example, there is no direction as to the scale or number of sites that are
required.
Nonetheless, regarding location, it is logical to look to deliver unmet development needs as close as possible to where they arise. This principle further supports the allocation of land adjacent to the southern edge of Coventry, including Land at Gibbet Hill, although this should be brought forward as an allocation rather than a reserve site.

No

ID sylw: 107941

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments 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: 107963

Derbyniwyd: 26/02/2025

Ymatebydd: Earlswood & Forshaw Heath Residents’ Association

During the period of the last (current) Local Plan, we wrote to you pointing out that Solihull MBC has been required to take a substantial number of houses that Birmingham could not accommodate from its LP. In excess of 12,000 have been built and most have been on the west side of Solihull as that is/was the only Green Belt space left to develop.

Solihull has, as you’re well aware, built right up to the District boundary and we are now the centre of shortcuts and rat-runs to avoid the congestion in central Solihull. You may have consulted with SMBC on this issue, in which case, you will be acutely aware of the developments but you have done nothing to alleviate our consequential issues such as the volumes of traffic using our lanes and the resultant traffic jams and deterioration of the road surfaces in general and very deep grooves created at the sides of the narrow lanes. The cross-boundary consultations with Solihull MBC, in particular, should have prepared SDC for this and a plan put in place to cover the period of the current Core Strategy.

The same issues apply to the developments in Bromsgrove and Redditch Districts as we’re being enclosed from the north and west too, although the traffic volumes are less.

No

ID sylw: 108062

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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.

Yes

ID sylw: 108111

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

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 Old Budbrooke Road, 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: 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.

Other

ID sylw: 108189

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy Direction 4- Accommodating Growth Needs Arising from Outside South Warwickshire? 2.41 Whilst St Philips 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, St Philips has some concerns regarding the SWLP’s proposed approach. 2.42 The SWLP proposes – albeit not explicitly – to only assist with addressing the unmet housing needs of the C&WHMA and GBBCHMA only when it these unmet needs are defined, and through the release of ‘reserve sites’. However, the PO does not identify, at this stage, any ‘reserve sites’, nor does the PO’s commentary on the proposed spatial strategy speak to this matter. 2.43 Importantly, 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) 2.44 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. 2.45 It is noted that there is no single, or definitive, approach to determining the proportion of unmet needs that any single area should accommodate. In any event, given that the SWLP area sits within the two HMAs, both with serious historic housing land supply challenges, St Philips considers that there is an extremely high level of certainty based on the current evidence that the SWLP will need to accommodate some of these needs. 2.46 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. 2.47 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. 2.48 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. 2.49 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). 2.50 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. 2.51 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) 2.52 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. This approach also aligns in principle with the approach adopted to distribute 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. 2.53 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. 2.54 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. St Philips 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. St Philips 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.

Other

ID sylw: 108206

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Paragraph 24 of the NPPF sets out the duty to cooperate, and Paragraph 36 is clear that for a plan to be positively prepared, unmet need from neighbouring areas must be accommodated where possible. Stratford forms part of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) and both Stratford and Warwick are in the Coventry and Warwickshire Housing Market Area. The latest position on housing need in the GBBCHMA is dated July 2020; this identified an unmet need of 40,325 dwellings, and a shortfall of 29,260 dwellings post-2031 in the Black Country alone. More recently, in the Birmingham Local Plan Review Preferred Options consultation document (July 2024), a shortfall of 46,153 dwellings over the period 2020 – 2042 was identified, with paragraph 3.5 stating that “the city will continue to be reliant on other local authorities to assist in meeting Birmingham's housing shortfall”. 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 there being significant shortfalls, in light of the scale of the previously evidenced shortfalls and the fact that various authorities in the HMAs have experienced significant increases in their housing requirements arising from the revised Standard Method, the Councils are encouraged to plan appropriately and allocate (reserve) sites for this purpose. It is considered that there is sufficient developable land in the large area of South Warwickshire to do so, as identified in the Strategic Growth Locations and potential new settlements, which can accommodate a significantly greater number of units than is required to meet Stratford and Warwick’s own needs. The Councils have a legal duty to cooperate and a responsibility to help address unmet needs, and for the SWLP Part 1 to be found sound, it is expected that it will need to do so.

Other

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.

Other

ID sylw: 108281

Derbyniwyd: 05/03/2025

Ymatebydd: David Kinnesley

Asiant : Fisher German

2.31 Paragraph 11 of the NPPF however further states that “Plans and decisions should apply a “presumption in favour of sustainable development…For plan-making this means that: strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” [our emphasis]. This is also again clear at Paragraph 69.

2.32 Stratford forms part of the Greater Birmingham and Black Country Housing Market Area and both Stratford and Warwick are within the Coventry and Warwickshire Housing Market Area. There are demonstrable unmet needs in both. Whilst these may have improved through the updated Standard Methodology for generating LHN, not least due to the removal of the 35% urban uplift, even with this removed there will still be unmet needs which can be quantified in the short term and positively dealt with through new allocations.

2.33 Given the acknowledged regional shortfalls and thus unmet need, this is an issue which needs to be grappled with at least provisionally in this Plan through the contribution of additional supply. We do not agree this should be inherently linked to the relevant 5-year supply of external authorities as ultimately this may be in dispute and regardless, unmet needs are present now which require response, not hypothetical unmet needs which will only emanate when they do not have a 5-year housing land supply. Clearly a housing land supply shortfall in that given authority will induce the presumption in favour and allow for that issue to be remedied locally. Unmet need is a strategic intervention and acknowledgement that authorities are unable to meet their requirements.

2.34 This Plan must therefore as an intrinsic part of its housing requirement provide for unmet needs, and again in terms of supply a sufficient buffer should be provided to ensure that the requirement is met in full in order to be in accordance with national policy and also positively prepared (which explicitly references unmet needs) and effective (NPPF Paragraph 36).

Other

ID sylw: 108296

Derbyniwyd: 05/03/2025

Ymatebydd: Bostrom Property LLP

Asiant : Fisher German

2.27 Paragraph 11 of the NPPF however further states that “Plans and decisions should apply a “presumption in favour of sustainable development…For plan-making this means that: strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” [our emphasis]. This is also again clear at Paragraph 69. 2.28 Stratford forms part of the Greater Birmingham and Black Country Housing Market Area and both Stratford and Warwick are within the Coventry and Warwickshire Housing Market Area. There are demonstrable unmet needs in both. Whilst these may have improved through the updated Standard Methodology for generating LHN, not least due to the removal of the 35% urban uplift, even with this removed there will still be unmet needs which can be quantified in the short term and positively dealt with through new allocations. 2.29 Given the acknowledged regional shortfalls and thus unmet need, this is an issue which needs to be grappled with at least provisionally in this Plan through the contribution of additional supply. We do not agree this should be inherently linked to the relevant 5-year supply of external authorities as ultimately this may be in dispute and regardless, unmet needs are present now which require response, not hypothetical unmet needs which will only emanate when they do not have a 5-year housing land supply. Clearly a housing land supply shortfall in that given authority will induce the presumption in favour and allow for that issue to be remedied locally, not through neighbouring release of land. Unmet need is a strategic intervention and acknowledgement that authorities are unable to meet their requirements as a fundamental part of Plan making. 2.30 This Plan must therefore as an intrinsic part of its housing requirement provide for unmet needs, and again in terms of supply a sufficient buffer should be provided to ensure that the requirement is met in full in order to be in accordance with national policy and also positively prepared (which explicitly references unmet needs) and effective (NPPF Paragraph 36).

Other

ID sylw: 108313

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

As set out elsewhere in CEG and Mixed Farms’ representations, it is important that the SWLP at this stage
considers the potential for unmet needs from outside South Warwickshire being met as the plan-making process
progresses.
For example, Birmingham’s unmet need of circa 37,900 dwellings as identified by the Birmingham Development
Plan (BDP, adopted 2017) is unlikely to have reduced as a result of the 2024 Standard Method figure for
Birmingham which now stands at 4,448 dwellings per annum versus the BDP housing requirement of 4,450
dwellings per annum.
CEG and Mixed Farms acknowledge that due to the new Standard Method being released only shortly before this
consultation commenced, there has not been sufficient time for evidence base studies to be undertaken to
establish the exact level of unmet need which may arise either from the Coventry and Warwickshire Housing
Market Area or from the Greater Birmingham and Black Country Housing Market Area.
At Regulation 19 stage however, CEG and Mixed Farms expect that this information will be available or better
understood, providing the opportunity for the SWLP to identify a quantum of development necessary to
accommodate unmet needs from neighbouring areas.

No

ID sylw: 108340

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Under the Duty to Co-operate, the Council is obliged to engage proactively with neighbouring authorities to address strategic cross boundary issues. This includes a potential need to accommodate ‘unmet need’ from the Coventry and Warwickshire Housing Market Area (HMA)
and the Greater Birmingham and Black Country HMA. While both Stratford and Warwick districts are located within the Coventry and Warwickshire HMA, only Stratford lies within the Greater Birmingham and Black Country HMA.

Draft Policy Direction 4 sets out how it is yet to be established to what extent there will be any unmet need from elsewhere within these housing market areas, however, the Councils will commit to “continually consider this need and work with those authorities on how this can be achieved.”

In this regard, Draft Policy Direction 4 suggests that 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.

Whilst this is commendable in theory, it is not understood how the Councils intend to allocate reserves sites through the SWLP when the scale or type of development need has not yet been determined. For example, there is no direction as to the scale or number of sites that are
required.

Nonetheless, regarding location, it is logical to look to deliver unmet development needs as close as possible to where they arise. This principle further supports the allocation of sites in the north and western parts of the Plan area, which includes Land North and South of Hill
Wootton Road.

Other

ID sylw: 108350

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We support the aspiration to meet the wider housing needs, especially the Coventry and Warwickshire HMA and the Greater Birmingham and Black Country HMA. We also support the decision to work closely with the Greater Birmingham and Black Country HMA to address any housing shortfalls. We are concerned that the HEDNA does not establish the extent of the wider unmet needs or the approach to addressing this to ensure the Duty to Cooperate is discharged.

Other authorities in the HMA such as Rugby, Birmingham, and the Black Country authorities, are facing significant increases in their housing need under the Standard Method. This will increase the acuteness of their housing shortfall.

We strongly urge the Councils to provide for a minimum of at least 2,188 dpa within the SWLP. In order to address the extent of the unmet housing needs, they should consider the opportunities of all potential sites in sustainable locations to existing settlements, including the Welsh Road West Site.

Other

ID sylw: 108366

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

6.1 Mackenzie Miller Homes welcomes the SWC’s acknowledgement that they may need to play
a role in addressing the unmet housing need of neighbouring authorities within C&WHMA
and GBBCHMA however, Mackenzie Miller Homes has some concerns regarding the
SWLP’s proposed approach.
6.2 The SWLP implicitly proposes to assist in addressing the unmet housing needs of the
C&WHMA and GBBCHMA, only when these needs are clearly defined, and through the
release of ‘reserve sites’. However, at this stage, the PO document neither identifies any
‘reserve sites’ nor does it address this issue in its commentary on the proposed spatial
strategy.
6.3 Notably, Paragraph 11b of the NPPF emphasises that LPAs must cooperate to identify and
meet housing needs within their housing market areas [HMA], and that plans should be
supported by relevant and up-to-date evidence as set out in Paragraph 32. It also reiterates,
in Paragraph 24, that LPAs’ continue to be under a DtC. In Paragraph 28 of the NPPF, 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.”
6.4 Given the severity of the situation in these HMAs, as detailed below, it is essential for the
SWLP to address any unmet housing needs from these HMAs at the time 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.
6.5 Whilst Mackenzie Miller Homes notes that there is no single, or definitive, approach to
determining the proportion of unmet needs that any single area should accommodate. In
any event, given that the SWLP area sits within the two HMAs, both with serious historic
housing land supply challenges, Mackenzie Miller Homes considers that there is an
extremely high level of certainty based on the current evidence that the SWLP will need to
accommodate some of these needs.
6.6 By way of example, there is some degree of uncertainty regarding whether there will be any
unmet housing needs arising from the C&WHMA, it is clear 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,1 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].2 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.
6.7 At present only the authorities set out in Table 1 below are proposing to contribute towards
these unmet housing needs:

6.8 Together, 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.
6.9 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
SWCs effectively delivering on their DtC.
6.10 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 SWCs and wider GBBCHMA
authorities will need to make appropriate contributions towards addressing these needs
now. Therefore, 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.
6.11 In terms of how much of these needs the SWCs 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).
6.12 However, as the SWCs 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.
6.13 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)
6.14 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.
6.15 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.
6.16 The above serves to highlight that there is evidence to suggest that the SWCs should be
seeking to make an appropriate contribution through the SWLP now, rather than deferring
it, in accordance with paragraph 35c of the NPPF. Mackenzie Miller Homes considers that
given the relatively modest contribution required of SOADC when compared to the SWC’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. Mackenzie Miller Homes also
considers that it is likely that there are sites throughout the SWLP area that could
sustainably contribute to addressing the SWC’s own housing needs and a proportion of the
GBBCHMA’s unmet housing needs.
6.17 Indeed, it is evident that there are opportunities to allocate ‘suitable, available and
achievable’ land and sites in sustainable locations across South Warwickshire of which,
Mackenzie Miller Homes’ Site in Shipston-on-Stour is considered as one of them.

Other

ID sylw: 108384

Derbyniwyd: 01/03/2025

Ymatebydd: Morgan Powell

Development is of course necessary. What is important to me is that Stratford and Warwick bear their fair share and not more - I read that Stratford District had the most new build houses completed in the country relative to the population for the period 2020 - 23, see https://www.bbc.co.uk/news/uk-england-coventry-warwickshire-68422097. It is time for other areas to bear a greater share.

Yes

ID sylw: 108401

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

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.

Additionally, the SWLP must integrate a robust duty-to-cooperate mechanism, reflecting the demographic, economic, and migration trends influencing South Warwickshire’s housing market.

Yes

ID sylw: 108434

Derbyniwyd: 06/03/2025

Ymatebydd: Mr R Wilding

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.

Additionally, the SWLP must integrate a robust duty-to-cooperate mechanism, reflecting the demographic, economic, and migration trends influencing South Warwickshire’s housing market.

Yes

ID sylw: 108454

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

Magdalen College, Oxford strongly supports 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).
It is important that this Local Plan is based on a Spatial Strategy that benefits from meaningful engagement between the authorities within the HMA. Paragraph 69 of the NPPF is clear 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.”
It is clear that the NPPF expects housing needs to be met in full and cross boundary working is a tool to achieve this. Given the general increase in housing need across the region following the 2024 NPPF, it seems more likely that places such as Coventry and Warwick, already constrained, will struggle to meet their housing needs within their administrative boundaries and South Warwickshire is a logical area to accommodate at least some of this unmet given the proximity and existing transport connections.
Whilst the College does not necessarily expect its 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.
As discussed above, small sites such as our clients land at Goose Lane, have an important role to play in ensuring a strong supply of deliverable sites across the Plan period.

Other

ID sylw: 108459

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

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.

Other

ID sylw: 108499

Derbyniwyd: 03/03/2025

Ymatebydd: Sally Rees

Failure to Adhere to the Duty to Cooperate (Chapter 2)
• South Warwickshire is being used to absorb housing overspill from Coventry and Solihull without transparent public consultation.
• The Plan must ensure that housing need is assessed locally, rather than simply accommodating external pressures.
Conclusion: The Plan must clarify how housing numbers are justified within South Warwickshire’s actual needs.

No

ID sylw: 108522

Derbyniwyd: 07/03/2025

Ymatebydd: Site Owner (Name Withheld)

Asiant : Nigel Gough Associates Ltd

The present consultation document does not take account of the government's statement issued jointly by The Rt Hon Angela Rayner MP and The Rt Hon Rachel Reeves MP focusing the new development opportunities for Iand surrounding commuter train stations such as the one at Claverdon where our Clients own the surrounding land to that station. We have issued separately a Legal Objection in respect of your present consultation because it does not include any focus on this new Directive.

Reserve sites should be allocated now in order to avoid the need for an early review of the Plan when unmet needs are eventually agreed.

Other

ID sylw: 108544

Derbyniwyd: 07/03/2025

Ymatebydd: Chapel Ascote Farms

Asiant : Framptons

Chapel Ascote Farms support recognition that there may be need to accommodate 'unmet need' from the Coventry & Warwickshire HMA and the Greater Birmingham and Black County HMA.

There is no detail to comment on at this stage. 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 be challenges for neighbouring authorities to meet their needs. The South Warwickshire authorities may well need to increase their housing need figures to accommodate unmet needs.

No

ID sylw: 108564

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

Paragraph 24 of the NPPF sets out the duty to cooperate, and Paragraph 36 is clear that for a plan to be positively prepared, unmet need from neighbouring areas must be accommodated where possible. Stratford forms part of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) and both Stratford and Warwick are in the Coventry and Warwickshire Housing Market Area. The latest position on housing need in the GBBCHMA is dated July 2020; this identified an unmet need of 40,325 dwellings, and a shortfall of 29,260 dwellings post-2031 in the Black Country alone. More recently, in the Birmingham Local Plan Review Preferred Options consultation document (July 2024), a shortfall of 46,153 dwellings over the period 2020 – 2042 was identified, with paragraph 3.5 stating that “the city will continue to be reliant on other local authorities to assist in meeting Birmingham's housing shortfall”. 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 there being significant shortfalls, in light of the scale of the previously evidenced shortfalls and the fact that various authorities in the HMAs have experienced significant increases in their housing requirements arising from the revised Standard Method, the Councils are encouraged to plan appropriately and allocate (reserve) sites for this purpose. It is considered that there is sufficient developable land in the large area of South Warwickshire to do so, as identified in the Strategic Growth Locations and potential new settlements, which can accommodate a significantly greater number of units than is required to meet Stratford and Warwick’s own needs. The Councils have a legal duty to cooperate and a responsibility to help address unmet needs, and for the SWLP Part 1 to be found sound, it is expected that it will need to do so.

No

ID sylw: 108574

Derbyniwyd: 07/03/2025

Ymatebydd: Site Owner (Name Withheld)

Asiant : Nigel Gough Associates Ltd

We agree with the approach to accommodating growth needs arising outside South Warwickshire. However, unmet housing need from the wider Housing Market Areas is not likely to be agreed for some time and this should not delay the SWLP in releasing significant land for development.
The allocation of reserve sites is a sensible approach, which would avoid the need for an early review when unmet needs become agreed. Reserve sites should be considered on a SWLP-wide basis. The SWLP should include a policy setting out clearly the circumstances under which a reserve site will be released for development.
We object as the Plan should clearly identify a range of suitable Reserve Sites at this stage of the Plan-making process to assist in providing land above the minimum of 2,188 dwellings per annum and thus confirm the "soundness" of the Plan.

Other

ID sylw: 108613

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 4 – Accommodating Housing Needs Arising from Outside South Warwickshire
4.34.
NPPF §24 sets out the duty to cooperate, and §36 is clear that for a plan to be positively prepared, unmet need from neighbouring areas must be accommodated where possible. Stratford forms part of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) and both Stratford and Warwick are in the Coventry and Warwickshire Housing Market Area. The latest position on housing need in the GBBCHMA is dated July 2020; this identified an unmet need of 40,325 dwellings, and a shortfall of 29,260 dwellings post-2031 in the Black Country alone. More recently, in the Birmingham Local Plan Review Preferred Options consultation document (July 2024), a shortfall of 46,153 dwellings over the period 2020 – 2042 was identified, with §3.5 stating that “the city will continue to be reliant on other local authorities to assist in meeting Birmingham's housing shortfall”. 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.
4.35.
In anticipation of there being significant shortfalls, in light of the scale of the previously evidenced work and the fact that various authorities in the HMAs have experienced significant increases in their housing requirements arising from the revised Standard Method, the Councils are encouraged to plan appropriately and allocate (reserve) sites for this purpose. It is considered that there is sufficient developable land in the South Warwickshire Plan Area to do so. This includes the Strategic Growth Locations and potential new settlements, which can accommodate a significantly greater number of homes than is required to meet Stratford and Warwick’s own needs. The Councils have a legal duty to cooperate
and a responsibility to help address unmet needs, and for the SWLP Part 1 to be found sound, it is expected that it will need to do so.

Yes

ID sylw: 108655

Derbyniwyd: 07/03/2025

Ymatebydd: Kingacre Estates Ltd (‘Kingacre’)

Asiant : Nexus Planning

Policy Direction 4 indicates that the SWLP will be underpinned by a housing need and availability evidence base that considers the Coventry and Warwickshire Housing Market Area (‘HMA’) as well as the Greater Birmingham and Black Country HMA. Kingacre supports the Councils’ commitment to developing an evidence base that will consider and seek to address ‘…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’.
Furthermore, the draft Policy Direction clarifies that should the evidence and the duty-to-cooperate process clearly indicate that ‘…there is a housing or employment need that cannot be met within the administrative boundaries of 12 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…’, then reserve sites will be released to meet that need.
Kingacre supports the Council’s commitment to meeting unmet needs arising, where evidenced, from other Authorities within the Coventry and Warwickshire HMA and Greater Birmingham and Black Country HMA. In meeting this commitment, the Council should identify specific sites that are set aside for these purposes and monitor their delivery independently of those sites allocated to meet the District’s own substantial housing needs.
Recommendation(s): a. Continue to develop an evidence base and policy position that assesses and seeks to meet identified unmet needs arising from Authorities in the Coventry and Warwickshire HMA and Greater Birmingham and Black Country HMA

No

ID sylw: 108663

Derbyniwyd: 07/03/2025

Ymatebydd: Cora

Asiant : Woolf Bond Planning

1. It is not justified as it fails to acknowledge that an uplift in the housing requirement is likely to be necessary to make a contribution towards unmet need in neighbouring authorities, including from the Cities of Coventry and Birmingham; and
2) Not consistent with national policy as it does not currently make a contribution towards unmet needs.
6.3 To address this matter of soundness: a) The Joint Plan area should include a contribution towards unmet needs arising outside of the Joint Plan area, including from the Cities of Birmingham and Coventry b) Additional allocations to be identified through the Local plan process, to include the allocation of our client’s land west of Southam Road, Kineton for around 160 dwellings (HELAA Ref: 452).