Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifyi
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Less 4 or more bed houses.
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None
Growth should be based on the sustainability of the County.
Develop a proper housing numbers plan based on: - Windfalls, where the numbers are regularly higher than that on which the forecasts are based. - Ignoring affordability uplifts, which is a (failed) political way to try and reduce house prices in the area and has nothing to do with actual requirements. - not driving "in-migration" by increasing house building in a self-replicating cycle of the more houses the more people will move to the area. Again, politically driven rather than actual requirements. - Rejecting the ‘Duty to Cooperate’ numbers from Birmingham and Coventry as these are over-stated and above their actual demographic need.
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Answer: Give full consideration to the CPRE assessment of HEDNA and undertake a review of use of brownfield sites, both within WDC and SDC but most importantly within neighbouring areas from which we are seemingly expected to take overflow numbers.
Regarding 4.1 The proposed requirement for hundreds of new houses in the area has been called into question and “The Office for National Statistics (ONS) is investigating the concerns that have been raised about out of date data being used to compile the HEDNA. Also a new study has been commissioned by WDC to look again at the figures.
South Warwickshire should not be required to commit to so many houses...42,000 by 2050 will ruin our rural district regardless of where the houses are built due to the sheer volume required. This volume of houses will be very bad for the environment as every house will have 2 cars and use a huge amount of energy.
HOUSING NEEDS – There has always been controversy about the magnitude of the numbers for housing needs and we have always known that they are (politically?) manipulated to fund affordable housing and overspill from the conurbations. The numbers deployed in the last Local Plan were repeatedly and credibly challenged, by Ray Bullen of BTPC and others, to little or no avail, and have since been shown to have been excessive. The pattern now looks likely to repeat itself… The JPC commends proper consideration of the CPRE review of the numbers along with a full review of the obligations to accommodate so many from the nearby conurbations.
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Q-H1-1 & 2: Providing the Right Number of New Homes 50. Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, HLM reserve its position in respect of whether this approach is reasonable for other authorities in Coventry and Warwickshire. 51. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals”4. National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. 52. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. 53. As set out in the appended South Warwickshire Housing Need Evidence Base Review Technical Report commissioned by HLM, whilst HLM support the housing need figures for South Warwickshire set out in the HEDNA, HLM have some concerns with the approach taken in the HEDNA to economic growth and affordable housing need. 54. On economic growth, whilst HLM agree with the demographic modelling assumptions used to calculate economic-led housing need in the HEDNA, the job growth assumptions require updating for the following reasons: The 2022 HEDNA’s Cambridge Econometrics (CE) job forecast is outdated (March 2021) and was generated during strict Covid-19 measures in the UK; CE are a robust source of job forecasts but a more recent forecast should be used; Assumed GDP informing the HEDNA’s job growth forecasts has now been shown to be an underestimate of growth by the Office for National Statistics; The higher GDP for 2021 and 2022 indicates job growth forecasts would be higher than those used by the HEDNA; Furthermore, job growth experienced in Warwick District and Stratford-on-Avon District during 2011 to 2019 significantly exceeded the CE forecast used to calculate economic-led housing need for the 2022-2043 period; It is unclear from the HEDNA whether economic growth on a number of sites within South Warwickshire are taken account of by the CE baseline projections. If not, these developments should be taken account of; The Council should consider job growth forecasts from Oxford Economics and Experian Economics alongside those from the CE. 55. HLM also consider that the significant level of unmet affordable housing needs across South Warwickshire should be taken into account in determining the housing requirement. The submitted analysis finds that the minimum housing need would be 1,609 dwellings per annum in Stratford-on-Avon District and 2,872 dwellings per annum to meet affordable housing needs based on past net delivery. Whilst it is recognised that this is significantly greater than the level of housing need set out in the HEDNA and is possibly unsustainable to deliver, this should influence the housing requirement through an appropriate uplift. 56. The enclosed analysis should be given consideration as the SWLP emerges, to ensure a sufficient level of housing is planned for across South Warwickshire. 57. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. 58. On the basis of the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. 59. In line with the NPPF5, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance6; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. 60. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness7, which is explored in further detail in response to Issue H4 below. 61. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, HLM consider that the SWLP will need to plan for a level of housing growth as set out in the below Table in the order of at least 43,000 dwellings. Table – SWLP Housing Requirement and Supply Calculation Housing Requirement South Warwickshire Minimum Housing Need Derived from the HEDNA (1,679 x 28 Years) --- 47,012 dwellings Uplift to Minimum Housing Need --- TBC – further work required to determine whether an uplift is appropriate Contribution Towards Unmet Needs of Coventry and Birmingham & Black Country --- TBC – engagement with Birmingham/Black Country and Coventry required but suggest increase of at least 21,000 dwellings possible (circa 11,000 towards Coventry and at least 10,000 towards Birmingham) Total Housing Requirement --- 68,000 dwellings + Housing Supply Sites with Planning Permission at 1st April 2022 (with 5% lapse rate applied) --- 14,360 dwellings Outstanding Local Plan Allocations at 1st April 2022 --- 5,579 dwelling Windfall Allowance --- TBC – 4,840 dwellings assumed in line with UCS however this requires further justification / compelling evidence Total Housing Supply --- 24,779 dwellings Indicative Housing Requirement to be found by the Plan --- 43,000 dwellings 4 Paragraph 61 of the National Planning Policy Framework (July 2021) 5 Paragraph 61 of the National Planning Policy Framework (July 2021) 6 Paragraph 010 Reference ID 2a-010-20201216 of National Guidance 7 Paragraph 35 a) of the National Planning Policy Framework (July 2021)
46. Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, HLM reserve its position in respect of whether this approach is reasonable for other authorities in Coventry and Warwickshire. 47. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals”4. National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. 48. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. 49. As set out in the appended South Warwickshire Housing Need Evidence Base Review Technical Report commissioned by HLM, whilst HLM support the housing need figures for South Warwickshire set out in the HEDNA, HLM have some concerns with the approach taken in the HEDNA to economic growth and affordable housing need. 50. On economic growth, whilst HLM agree with the demographic modelling assumptions used to calculate economic-led housing need in the HEDNA, the job growth assumptions require updating for the following reasons: The 2022 HEDNA’s Cambridge Econometrics (CE) job forecast is outdated (March 2021) and was generated during strict Covid-19 measures in the UK; CE are a robust source of job forecasts but a more recent forecast should be used; Assumed GDP informing the HEDNA’s job growth forecasts has now been shown to be an underestimate of growth by the Office for National Statistics; The higher GDP for 2021 and 2022 indicates job growth forecasts would be higher than those used by the HEDNA; Furthermore, job growth experienced in Warwick District and Stratford-on-Avon District during 2011 to 2019 significantly exceeded the CE forecast used to calculate economic-led housing need for the 2022-2043 period; It is unclear from the HEDNA whether economic growth on a number of sites within South Warwickshire are taken account of by the CE baseline projections. If not, these developments should be taken account of; The Council should consider job growth forecasts from Oxford Economics and Experian Economics alongside those from the CE. 51. HLM also consider that the significant level of unmet affordable housing needs across South Warwickshire should be taken into account in determining the housing requirement. The submitted analysis finds that the minimum housing need would be 1,609 dwellings per annum in Stratford-on-Avon District and 2,872 dwellings per annum to meet affordable housing needs based on past net delivery. Whilst it is recognised that this is significantly greater than the level of housing need set out in the HEDNA and is possibly unsustainable to deliver, this should influence the housing requirement through an appropriate uplift. 52. The enclosed analysis should be given consideration as the SWLP emerges, to ensure a sufficient level of housing is planned for across South Warwickshire. 53. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. 54. On the basis of the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. 55. In line with the NPPF5, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance6; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. 56. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness7, which is explored in further detail in response to Issue H4 below. 57. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, HLM consider that the SWLP will need to plan for a level of housing growth as set out in the below Table in the order of at least 43,000 dwellings. Table – SWLP Housing Requirement and Supply Calculation Housing Requirement South Warwickshire Minimum Housing Need Derived from the HEDNA (1,679 x 28 Years) --- 47,012 dwellings Uplift to Minimum Housing Need --- TBC – further work required to determine whether an uplift is appropriate Contribution Towards Unmet Needs of Coventry and Birmingham & Black Country --- TBC – engagement with Birmingham/Black Country and Coventry required but suggest increase of at least 21,000 dwellings possible (circa 11,000 towards Coventry and at least 10,000 towards Birmingham) Total Housing Requirement --- 68,000 dwellings + Housing Supply Sites with Planning Permission at 1st April 2022 (with 5% lapse rate applied) --- 14,360 dwellings Outstanding Local Plan Allocations at 1st April 2022 --- 5,579 dwellings Windfall Allowance --- TBC – 4,840 dwellings assumed in line with UCS however this requires further justification / compelling evidence Total Housing Supply --- 24,779 dwellings Indicative Housing Requirement to be found by the Plan --- 43,000 dwellings + 4 Paragraph 61 of the National Planning Policy Framework (July 2021) 5 Paragraph 61 of the National Planning Policy Framework (July 2021) 6 Paragraph 010 Reference ID 2a-010-20201216 of National Guidance 7 Paragraph 35 a) of the National Planning Policy Framework (July 2021)
The NPPF 2012 introduced a radical shift in relation to the approach to meeting housing needs. This remains in the 2021 version where at paragraph 8 it outlines the three overarching objectives to securing sustainable development and paragraph 8b states that to achieve the ‘social objective’ it is necessary to “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations…” Paragraph 60 of the NPPF then states that “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” However, despite the additional requirements and objectives imposed by the NPPF, it is widely accepted that there is a national housing crisis due to the consistent failure to achieve the Government’s target of 300,000 homes per annum, with affordability unsurprisingly worsening across many parts of the country, year on year. On 6 December 2022, Secretary of State Michael Gove announced the Government’s intentions via a Written Ministerial Statement (“WMS’”) to make fundamental changes to the planning system, which were then set out in a NPPF prospectus (“the prospectus”), published for consultation on 23 December 2022. On 8 December 2022, the Planning Inspectorate set out clear guidance (PINS NOTE 14/2022) which confirms that the WMS set out proposals for consultation only, rather than immediate changes to Government policy. It is therefore the case that in the interests of plan-making, the requirements of the existing NPPF (published July 2021) still apply. Given the above, these representations do not therefore focus on the content of the draft changes, but it is of note that the Government remains committed to its target of achieving 300,000 homes per year. Accordingly, it is vital the SWLP sets a positive framework to fully accommodate its housing needs and importantly address existing underlying issues as well. The NPPF is clear at paragraph 61 that housing need should be calculated using the Government’s Standard Method unless there are exceptional circumstances to justify an alternative approach. The HEDNA outlines a rationale for applying a trend-based approach for which there is merit but noting the test of national policy for such an approach, it is considered that further justification is still required in this regard. However, regardless of whether the standard method is used, based on the 2014-based projections, or whether the alternative trend-based projection is used, this should still only be the starting point for determining the housing requirement for the Plan. The Plan acknowledges that there will likely be a need to accommodate some unmet housing needs from adjoining authorities which of course represents one potential uplift (addressed in response to a separate question), but it is suggested that an affordability adjustment should also be applied. The Plan confirms that, across the Plan area, the median house price to income ratio is over 10.5. For Stratford-upon-Avon District, the affordable housing need identified in the Table 10 of the Plan is some 547 dwellings per annum. When this is compared to the overall housing need for the District, stated at Table 9 of the Plan, affordable housing need would equate to 96% of the 13 total housing need using the 2014-based projections, or 63% using the trend-based projections. The situation in Warwick District is worse still. Affordability is an on-going and increasing pressure which will require a proactive approach that should be rooted in increasing the housing requirement given that market led housing schemes have, and will continue, to deliverthe biggest supply of affordable homes.
The NPPF is clear that: 2.56 “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” (Para 11b) (Emphasis added). 2.57 It also states that: 2.58 “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance…” (Para 61) 2.59 In this context, it is noted that the 2021 Scoping Consultation set out the housing need context for the SWLP, highlighting that the SWLP housing requirement is underpinned by the Local Housing Need (LHN) figure generated by the Standard Method. For the SWLP area, on the whole, the Scoping Consultation stated that the SWLP will need to deliver a minimum of 1,230 new homes each year, or c.35,000 dwellings over the 30-year plan period. St Philips considers that the Council’s proposed strategy is acceptable in principle and that the deviation from the Standard Method is enabled by the NPPF and PPG. As acknowledged above, NPPF paragraph 61 states that the local housing need figure determines the minimum number of homes needed. Therefore, an uplift can be applied when supported by evidence. As acknowledged within the Issues and Options document, subsequent to the release of the 2014-based projection, based on more up-to-date assumptions about fertility, mortality and household formation rates, the Housing and Economic Development Needs Assessment (HEDNA) applied alternative projections through the framework provided by the standard method. St Philips considers this deviation to be acceptable in principle. Based off of the trend based projections as presented within the HEDNA, the overall housing need within South Warwickshire has increased when compared to the 2014-based projection from 1,239 dwellings per annum (dpa) to 1,679 dpa. In this instance, South Warwickshire will have to provide a greater supply of deliverable sites in order to meet this greater housing need. St Philips considers that the identification of a variety of suitable sites would accord with paragraph 60 of the NPPF which clearly states that: “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” As stated above, the use of the HEDNA and the Council’s deviation from the Standard Method is acceptable in principle. As recognised by the Issues and Options Consultation, the standard method framework is the starting point for assessing the housing need. Both the NPPF3 and PPG4 are clear that the LHN figure generated by the standard method is a minimum starting point (i.e. actual housing need may be higher than this figure). Moreover, elsewhere in the guidance, the PPG differentiates between the minimum figure arrived at through the standard method and ‘actual’ housing need which can be higher. Although the HEDNA deviates from the LHN, it is highly likely that an additional uplift will be required as discussed in more detail within the response to question H4 below. It is ‘actual’ housing need that represents the objectively assessed need to which the tests in paragraph 11 of the NPPF apply, and there is also a requirement for the Council to test reasonable alternatives5. Therefore, the Council should actively identify whether there are reasons for testing higher figures as estimates of housing need. Fundamentally, this is because the standard method does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour, nor considers local factors, policy and aspiration which might legitimately mean the Council should seek to plan for more homes than the minimum. The PPG goes on to state that it would be appropriate for a higher figure to be adopted on the basis of employment, infrastructure, affordable housing or unmet housing needs. In this regard, St Philips recommends that the SWLP should seek to deliver a greater number of dwellings over and above the housing need figure set out by the HEDNA. As discussed below, the substantial level of demand for affordable housing within South Warwickshire justifies an uplift to the objectively assessed need figure identified within the HEDNA in order to address the worsening affordability within the area. In the context of affordable housing, whilst the Standard Method includes an adjustment to take account of the median affordability ratio, the PPG7 is clear that an increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes. In addition to addressing the affordable housing requirement within South Warwickshire, the scale of the unmet housing needs emerging from within the Coventry and Warwickshire Housing Market Area (C&WHMA) and GBBCHMA (c.78,000 dwellings) are likely to require an uplift to the housing need figure for South Warwickshire as identified by the HEDNA. The requirement to accommodate these needs is set out below within the response to question H4.
The NPPF is clear 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” (Para 11b). 2.36 It also states that: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance…” (Para 61). 2.37 In this context, it is noted that the 2021 Scoping Consultation set out the housing need context for the SWLP, highlighting that the SWLP housing requirement is underpinned by the Local Housing Need [LHN] figure generated by the Standard Method. For the SWLP area, on the whole, the Scoping Consultation stated that the SWLP will need to deliver a minimum of 1,230 new homes each year, or c.35,000 dwellings over the 30-year plan period. 2.38 St Philips considers that the Council’s proposed strategy is acceptable in principle and that the deviation from the Standard Method is enabled by the NPPF and PPG. As acknowledged above, NPPF paragraph 61 states that the local housing need figure determines the minimum number of homes needed. Therefore, an uplift can be applied when supported by evidence. As acknowledged within the Issues and Options document, subsequent to the release of the 2014-based projection, based on more up-to-date assumptions about fertility, mortality and household formation rates, the Housing and Economic Development Needs Assessment [HEDNA] applied alternative projections through the framework provided by the standard method. St Philips considers this deviation to be acceptable in principle. 2.39 Based off of the trend based projections as presented within the HEDNA, the overall housing need within South Warwickshire has increased when compared to the 2014-based projection from 1,239 dwellings per annum [dpa] to 1,679 dpa. In this instance, South Warwickshire will have to provide a greater supply of deliverable sites in order to meet this greater housing need. 2.40 St Philips considers that the identification of a variety of suitable sites would accord with paragraph 60 of the NPPF which clearly states that: “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” As stated above, the use of the HEDNA and the Council’s deviation from the Standard Method is acceptable in principle. As recognised by the Issues and Options Consultation, the standard method framework is the starting point for assessing the housing need. Both the NPPF3 and PPG4 are clear that the LHN figure generated by the standard method is a minimum starting point (i.e. actual housing need may be higher than this figure). Moreover, elsewhere in the guidance, the PPG differentiates between the minimum figure arrived at through the standard method and ‘actual’ housing need which can be higher. Although the HEDNA deviates from the LHN, it is highly likely that an additional uplift will be required as discussed within the response to question H4 below. 2.42 It is ‘actual’ housing need that represents the objectively assessed need to which the tests in paragraph 11 of the NPPF apply, and there is also a requirement for the Council to test reasonable alternatives5. Therefore, the Council should actively identify whether there are reasons for testing higher figures as estimates of housing need. 2.43 Fundamentally, this is because the standard method does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour, nor considers local factors, policy and aspiration which might legitimately mean the Council should seek to plan for more homes than the minimum. The PPG goes on to state that it would be appropriate for a higher figure to be adopted on the basis of employment, infrastructure, affordable housing or unmet housing needs.6 2.44 In this regard, St Philips recommends that the SWLP should seek to deliver a greater number of dwellings over and above the housing need figure set out by the HEDNA. As discussed below, the substantial level of demand for affordable housing within South Warwickshire justifies an uplift to the objectively assessed need figure identified within the HEDNA in order to address the worsening affordability within the area. 2.45 In the context of affordable housing, whilst the Standard Method includes an adjustment to take account of the median affordability ratio, the PPG7is clear that an increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes. 2.46 In addition to addressing the affordable housing requirement within South Warwickshire, the scale of the unmet housing needs emerging from within the C&WHMA and GBBCHMA (c.78,000 dwellings) are likely to require an uplift to the housing need figure for South Warwickshire as identified by the HEDNA. The requirement to accommodate these needs is set out below within the response to question H4
Issue H1: Providing the right number of new homes: I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
Providing the right number of new homes: I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
Issue H1: Providing the right number of new homes: I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.