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
Question H1.1: Taylor Wimpey generally support the proposed trend-based approach using the 2021 census data, which has resulted in an increase of 440 homes per year in comparison with the 2014-based projections. 3.32 It will be important that the CWHMA authorities provide the adequate evidence and justification to support deviating from the current, and potentially future, standard method for calculating local housing need.
Based on the following 6 points there is no need to appropriate more land for housing development : WINDFALLS • The SWLP allows for land for 220 dwellings per annum (DPA) from windfalls. • Actual annual average windfall numbers since 2011 have been 901. • 69% of Stratford’s housing site needs since 2011 have been met from Windfalls; 44% of Warwick’s. • If instead of 220 DPA’s (as in plan) the SWLP assumed only half the annual average, (450 homes) the housing land shortfall drops from 23,000 to 1510 in 2040; 5,410 in 2045 and 9310 in 2050. • If the actual average since 2011 – 901 - is used, the plan is in surplus: 5,255 excess house spaces in 2040; 3610 excess in 2045. 1965 in 2050. • In addition to a severe underestimate of overall numbers, the Local Planning guidance only includes within the 220, those spaces for fewer than 9 dwellings. So places like the Ford Foundry site, the King’s High School sites, land adjacent to Leamington Spa Station, and others for more than 9 homes would not be included. • I believe that this also seriously distorts likely available land, based on figures since 2011. AFFORDABILITY UPLIFTS Under a formula devised in 2004, housing numbers are automatically increased in more expensive areas, on the assertion that building more houses will bring down prices. This has nothing whatsoever to do with actual housing need. ONS numbers from the base year used (2014) assessed the SWLP area need at 874 homes. The Affordability formula increases this to 1,239. These are the numbers used in the SWLP. This is an increase of 42% over need. IN-MIGRATION • Housing numbers like Coventry’s encourage net in-migration to local areas. They are not a response to endogenous growth. • 76% of Warwick’s estimated population growth for 2018-2028 comes from net in-migration. • 118% of Stratford’s is from the same source. (ie. Just on birth rate, without in-migration, the population would decline). • This therefore risks becoming a self-replicating cycle. (“We’ve filled more houses, therefore we need more houses, therefore…”) DUTY TO CO-OPERATE • Housing was built in the SWLP area as a response to Coventry’s overestimates, destroying swathes of prime farmland in the process. • This is part of the ‘Duty to Cooperate’ imposed on neighbouring areas, when the ‘growing’ area does not have the requisite space. • The government has added 35% to assessed need in 20 key cities. (In theory this means that more urban brownfield sites are used.) Applying this to Birmingham gives them three times their demographic need. • Birmingham (for whom Gerald has also produced an excellent report) does not have space for these numbers. • This potentially means that over the plan period South Warwickshire will have to build houses they don’t want for a Birmingham need that doesn’t exist. • The Black Country (also subject to one of Gerald’s Reports) has currently abandoned its Local Plan for similar reasons. EMPLOYMENT LAND NEEDS • I would ask those responsible for the SWLP to reconsider Employment land needs. • Numbers don’t reflect the estimated 30% reduction in office space post-Covid. • There is also a visible increase in Town Centre vacant retail sites across the region. • In particular, Stratford is estimated to need 132.8Ha (333 acres) of Industrial Land. • This puts it only behind Rugby (Cement and extraction) and Coventry (automotive). TIMEFRAME • The SWLP framework extends from 2025 to 2050, to allow for long-term infrastructure planning. • This is considerably longer than most planning frameworks. • Increasing the plan from the more usual 15 years, increases SWLP housing numbers by 50%. (And therefore countryside blight). • Remaining with 15 years, instead of 35,000 houses by 2050 we would be looking at 23,370 by 2040.
Q-H1-1: The latest HEDNA suggests exceptional circumstances exist to move away from the Standard Method for determining housing need as there are alleged issues with existing census data in estimating and projecting the population in Coventry. 4.4 The HEDNA has therefore modelled new demographic projections which take account of the initial 2021 Census data releases and seeks to assess how the population can be expected to change over time by applying more up-to-date assumptions about fertility, mortality and household formation rates. The HEDNA then applies these alternative projections through the framework provided by the standard method. The HEDNA suggests that, based upon the trend-based projections, whilst the housing need in Coventry City may have reduced, the housing need for Stratford-on-Avon has increased from 564 to 868 dwellings per year (304 dwellings per year / 53.9% increase). Similarly, the need for Warwick District has increased from 675 to 811 dwellings per year (136 dwelling per year / 20.1% increase). The total housing need for both Districts (and therefore South Warwickshire) has accordingly increased from 1,239 to 1,679 dwellings per year (440 dwellings per year / 35.5% increase). 4.6 The housing need across the Plan Period has therefore increased from 30,975 to 41,975. This figure represents the minimum need that should be planned for and does not includ e any unmet need from neighbouring authorities (such as Coventry or Birmingham) which may be accommodated, or any additional homes that may be planned for to meet other socio-economic objectives (such as increasing affordable housing provision – see answer to Question H2-2). 4.7 Should the authorities choose to pursue the trend-based alternative, they must accept that their housing need increases substantially and that this need must be met, as a minimum. It would not be acceptable to reduce the level of housing provided within Co ventry whilst seeking to retain the need for Stratford and Warwick suggested by the Standard Method.
No answer given
Yes. The HEDNA is considered to accord with NPPF para 61, whereby it provides evidence that exceptional circumstances justify the use of an alternative approach (trend-based) to determine the minimum number of homes needed, rather than utilising the 2014-based household projections due to its evident inconsistencies with the resulting housing need figure for Coventry. Given that the South Warwickshire councils share a Housing Market Area (HMA) with Coventry and the neighbouring councils North Warwickshire, Nuneaton and Bedworth and Rugby, the South Warwickshire Local Plan provides an opportunity to consider the local housing needs in consideration of the up-to-date household figures within the HMA. It is noted that the trend-based figures identified in the HEDNA result in a higher local housing need than the standard method based on the 2014 household projections. The council should ensure that a sufficient supply of housing sites, including affordable, is provided, in line with the Government’s aim of significantly boosting the housing land supply in accordance with NPPF para 60. However, consideration should be given to the unmet needs from Birmingham, given the overlap of the HMA with the Birmingham HMA, Further evidence should be provided to understand the population movements and projections within the wider housing market. The Greater Birmingham HMA Strategic Growth Study (GL Hearn, February 2018), which built on the Birmingham Strategic Growth Study 2 Report (PBA 2014) and Strategic Housing Needs Study (PBA, 2015), notes that Birmingham’s functional HMA extends to include the Black Country, parts of Worcestershire, Staffordshire and Warwickshire, which is also confirmed within the 2022 Birmingham HEDNA. The Birmingham HMA includes part of Stratford-on-Avon district and given the overlap between Birmingham and Coventry/Warwickshire HMA. NPPF (2021) para 61 states that “any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”. It is therefore considered essential that the joint evidence provided from neighbouring authorities within overlapping HMAs should be taken into account when making provision to meet the wider HMA housing needs. The HEDNA should therefore be expanded to consider the wider HMA. In particular, the assumed split of in-migration from the overlapping Birmingham HMA, based on past trends, should be considered. The Birmingham HEDNA demonstrates that on average, there were between approximately 7,000 to 10,500 net moves per annum from Birmingham to the wider HMA between 2015 to 2020. Therefore, additional evidence should be provided to take account of internal migration flows from Birmingham. The Birmingham HMA Strategic Growth Study states that the evidence points to a baseline / minimum level of housing need for 205,000 to 264,600 homes from 2011 to 2031 and between 256,000 and 310,000 to 2036 (2011 baseline) in the Birmingham HMA, which extends into Warwickshire. The report notes that Stratford-on-Avon is contributing 2,020 dwellings to 2031, extending to 3,600 until 2036 if measured on a pro-rata basis. With consideration of the land supply to 2031 (179,829) and 2036 (197,618), the minimum shortfall in the HMA to 2031 and 2036 is 28,150 and 60,855 respectively. The report notes that Stratford’s Core S trategy is making provision for 5,440 dwellings to meet unmet needs of other areas, of which 50% contributes to meeting unmet needs in the Coventry and Warwickshire HMA and Birmingham HMA respectively. The evidence provided, particularly the trend-based approach based on 2021 projections, as opposed to the 2014 projections, appears to provide a reasonable basis in light of the evident issues with Coventry based figures. However, a further analysis of the wider housing market area (HMA), including the Birmingham HMA, and the likely movements from the wider HMA into Stratford-on-Avon and Warwick is necessary to address the local housing need. Additionally, given that evidence of Coventry’s level of unmet need may not be available within the timescales of the South Warwickshire local plan process, there may be a need for the provision of additional housing land supply to ensure the unmet needs from Coventry can be met. It is understood that the South Warwickshire Councils are currently engaging with Birmingham City Council to seek agreement on a Memorandum of Understanding to ensure that unmet needs can be met. We would welcome the agreement to form part of the evidence base for the next stage in the local plan to provide certainty of the local housing needs. We expect that South Warwickshire will need to take on some of the unmet needs of the Birmingham HMA, given their significant shortfall.
3.35 The NPPF mandates the use of the 2014 subnational household projections (SNHP) in the Standard Method and following the relevant Planning Practice Guidance (PPG) the method shows a need for 5,554 dwellings per annum across the Housing Market Area (HMA). 3.36 The PPG does however allow for authorities to diverge from the Standard Method where this can be justified by exceptional circumstances; any alternative approach should reflect current and future demographic trends (which includes migration) and market signals. The HEDNA proposes an alternative ‘trend-based’ projection, which is set out at Table 9 of the I&O consultation document. RPS broadly agrees that this is justified on the evidence. For example, in South Warwickshire there is a case for higher housing provision to be made over and above the standard method starting point in order to manage cross-boundary commuting which currently shows a net-in flow into the area to access local employment. This is outlined in Issue E3 (page 81 of the consultation document), “It is important to ensure that South Warwickshire is attracting a mix of employment to the area which will help to prevent out-commuting and retain residents within South Warwickshire”. 3.37 In this regard, RPS welcomes the use of a ‘trend-based’ projection as set out in the consultation.