Q-H4-1: Do you agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-on-Avon District?

Showing forms 91 to 120 of 254
Form ID: 77214
Respondent: Mr Stephen Lawless

No

No answer given

No answer given

Form ID: 77329
Respondent: Mrs P A Coates

No

No answer given

No answer given

Form ID: 77346
Respondent: Mr Toby Lee

No

Stratford-upon-Avon Town Council made an objection to the policies proposed in the June 2022 preferred option position from Stratford On Avon District Council. So far the District Council has not corresponded with the Town Council on this matter. Details of why the Town Council opposes the policies proposed are set out in the response provided by the Town Council to the District Council.

Use a policy approach that considers all of the district, not just Stratford-upon-Avon.

Form ID: 77464
Respondent: Jenny Bevan

No

It shouldn't be up to South Warwickshire to accommodate their shortfall! As previous responses have said, it should be provided as close to the origin of the person as possible.

Absolutely as close as possible to the shortfall places NOT south Leamington. If there needs to be building in the green belt rather than south Leamington so be it.

Form ID: 77569
Respondent: Mr Shannon Moore

Nothing chosen

I am opposed to releasing green belt land or developing significant developments that will adversely impact on the nature of the local areas. Brown field sites and infill should be used rather than rural areas. Birmingham and the Black Country should be assisted to convert their brown field sites first.

See above

Form ID: 77606
Respondent: Dr Kathryn Carpenter

No

Resist building housing for Birmingham and Black Country unless forced by central government.

No answer given

Form ID: 77616
Respondent: Mr Andrew Klapatyj

Yes

No answer given

No answer given

Form ID: 77653
Respondent: Campaign to Protect Rural England - Warwickshire

No

CPRE's submitted report explains why the level of shortfall (or unmet need) arising in Birmingham is exaggerated. It attaches CPRE West Mildands Region's report on the Birmingham Plan Review Issues & Options and the Birmimngham HEDNA (2022). The SWLP Issues & Options consultation papers refer to a 37,900 houses shortfall (to 2031) in the Birmingham Plan as established. This is out of date and incorrect. According to the 2020 Joint Statement on Housing Need and Supply (GBBCHMA I), in the two years since adoption in 2017 (up to 2019), sites for 13,942, or 27% additional housing supply has been found in Birmingham. This shows, among other things the impact of under-estimating windfalls in a local plan. Within two years the shortfall, even if everything else is correct, has been found to fall to 23,958 dwellings, only 63% of the figure in the Plan. By the 2021 addendum (GBBCHMA II) this had risen to an additional 16,071, or 31% of supply, reducing the shortfall to 21,829, (58% of the shortfall) so one would expect it to fall further. The current Birmingham Plan Issues and Options work continues to undercount likely windfalls as well as exaggerating households in Birmingham (demonstrated by comparison of its projected figures with actul population in the 2021 Census). It may fall again when updated ONS figures feed into the next iteration of the plan. Detailed comments on the supposed short fall of 78,415 in Birmingham from WM CPRE are attached as an appendix to our report on Housing Need and Supply and demonstrate the weakness of the case for an overspill. Similarly, the previous shortfall associated with the (now abandoned) Black Country Plan is not consistent either with the 2021 Census results, or with the recent (Chilmark) report on brownfield capacity in the Black Country. Both are addressed in CPRE WM's report (also appended) on the Regulation 18 consultation which was reached, before work on that Plan ceased. CPRE considers it likely that when the individual Plans of the four Black Country boroughs emerge the shortfall in the Black Country area will look very different and may not exist at all. In other words, we do not believe the SWLP should provide any additional land for that unmet need. Indeed, if it were to seek to allocate Green Belt land for housing development, then exceptional circumstances would not exist.

For the reasons given in CPRE's submitted report and the analysis of housing numbers included in the two supporting appraisals (Birmingham Plan Review (I&O) and the Black Country Plan (abandoned at Reg 18 stage), we do not consider that there are housing shortfalls from either that will need to be accommodarted in South Warwickshire.

Form ID: 77679
Respondent: Hallam Land Management Limited (HLM)
Agent: Marrons

Nothing chosen

It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF8. It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above HLM consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases9, an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.

No answer given

Form ID: 77680
Respondent: Hallam Land Management Limited (HLM)
Agent: Marrons

Nothing chosen

No answer given

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include Southam.

Form ID: 77685
Respondent: Mr Steven Hughes

No

No answer given

No answer given

Form ID: 77703
Respondent: William Davis Limited
Agent: Marrons

Nothing chosen

No answer given

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, William Davis consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Greater Birmingham’s unmet needs, this should include Studley given its relationship to Redditch.

Form ID: 77706
Respondent: Trenport Investments Ltd
Agent: WSP UK

Yes

It is both reasonable and suitable for South Warwickshire to accommodate a reasonable proportion of the shortfall from the Birmingham and Black Country HMA. In addition to the LPA’s duty to cooperate on strategic matters, there are additional suitable sites within the South Warwickshire area capable of delivering this housing. Particularly suitable sites include those that are not located within the Green Belt or the Cotswolds National Landscape (formerly Area of Outstanding Natural Beauty), are available now, offer a suitable location, and can achieve housing delivery within five years.

Housing should be delivered on sites which are: not located within the Green Belt or the Cotswolds National Landscape (formerly Area of Outstanding Natural Beauty); are available or will become available; are in sustainable locations; and can achieve housing delivery within five years. Housing delivery should be dispersed across the LGA, in accordance with this spatial growth option. This approach will enable increased supply across a wider geographic range to help meet needs across the whole LGA rather than only focused urban areas. Our clients can provide a sustainable and deliverable site to help accommodate this shortfall in housing. The land is located north of Old School Lane, Lighthorne. The site does not fall within the Green Belt or the Cotswold National Landscape, and is located close to the emerging Gaydon/Lighthorne Heath village centre. It is in Flood Zone 1 and is not constrained by any archaeological or ecological restrictions. The site is also in one ownership, and therefore development is achievable within the next five years.

Form ID: 77713
Respondent: Stratford-on-Avon Town Council

No

The Town Council refers this consultation to the consultation response made to the 2022 Site Appraisal Consultation issued by Stratford On Avon District Council.

The Town Council refers this consultation to the consultation response made to the 2022 Site Appraisal Consultation issued by Stratford On Avon District Council.

Form ID: 77728
Respondent: Hallam Land Management Limited (HLM)
Agent: Marrons

Nothing chosen

No answer given

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include Kenilworth given its rail and bus links.

Form ID: 77731
Respondent: Ms Rachel Pope

No

Such a move would not reflect the current national policy position. The emerging changes to the NPPF remove the requirement to satisfy unmet need from neighbouring authorities. In addition, as mentioned above, housing need figures should just be a "starting point" and do not need to be doggedly pursued if they would involve building on Green Belt land. This should be borne in mind for other overspill issues.

Such a requirement seems unlikely given the national policy position. The emerging changes to the NPPF remove the requirement to satisfy unmet need from neighbouring authorities. In any case, shortfalls should not be accommodated in the Green Belt as housing need figures are just a "starting point" which do not need to be pursued if they would involve building on Green Belt land or other land where genuine constraints exist.

Form ID: 77751
Respondent: Hallam Land Management Limited (HLM)
Agent: Marrons

Nothing chosen

No answer given

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should be land south of Coventry.

Form ID: 77778
Respondent: Mr Ian Fradgley

No

I would like to see what the additional numbers of homes Birmingham and the Black Country are proposing that they will need - since I travel regularly through the Black Country they have plenty of local undeveloped sites which should be developed first.

No answer given

Form ID: 77779
Respondent: Mr Craig Mander

No

South Warwickshire should under no circumstance choose to take more additional growth, this would put additional serious pressure on services, infrastructure, important habitats and environments in the area. The other Councils need to legitimately look to find land/ increase housing densities in their local areas. Especially as it would appear Birmingham has copious brown field sites which could be utilised which would be preferable to using green belt land.

We should not and appropriate strong objection is needed against this. If Stratford Council fails in this and is forced then more high quality duplex flats should be built with decent sound proofing, balconies, roof terrace/garden space. As we do not have enough land in the UK to allow for agriculture, wild space and enough housing we need to be utilising our air space more. Flats would be more desirable in the UK if they were built properly. We can not continue with everyone’s wish for a 4-bed detached house with a garden. There is not enough room.

Form ID: 77810
Respondent: Richborough Estates
Agent: Marrons

Nothing chosen

It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF . It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above Richborough Estates consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases , an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.

No answer given

Form ID: 77819
Respondent: Richborough Estates
Agent: Marrons

Nothing chosen

No answer given

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Richborough Estates consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include Kenilworth given its rail and bus links.

Form ID: 77832
Respondent: Richborough Estates
Agent: Marrons

Nothing chosen

No answer given

66. With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Richborough Estates consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry and Birmingham’s unmet needs, this should include Warwick given its rail links.

Form ID: 77849
Respondent: Finham Brook Flood Action Group

No

No answer given

No answer given

Form ID: 77875
Respondent: Mrs Jayne Mills

No

It is ridiculous to ruin the green belt to accomodate so many people from Birmingham.

Coventry has so many students that there is no room for housing normal people. The Universities should give something back financially to resolve the issue and help to develop poorer areas in Coventry.

Form ID: 77925
Respondent: Countryside Properties
Agent: Marrons

Nothing chosen

It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF . It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above Countryside Properties consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases , an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Wellesbourne was recognised within the Greater Birmingham HMA Strategic Growth Study (2018) as a sustainable settlement free from significant statutory constraints, and capable of accommodating further growth. Countryside Properties therefore support Wellesbourne contributing towards meeting unmet needs from the Greater Birmingham HMA.

Form ID: 77930
Respondent: Great Alne Parish Council

Yes

I accept the principle but would not wish to have shortfalls from Birmingham and Black Country HMA accommodated at the expense of housing for existing South Warwickshire residents

Ideally, In order to optimise sustainability and minimise adverse impact on climate change, such shortfalls should be (a) accommodated in new settlements, and (b) located as closely as possible to the areas from which they originate.

Form ID: 77950
Respondent: Bloor Homes Western
Agent: Marrons

Nothing chosen

It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF . It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above Bloor Homes consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases , an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.

No answer given

Form ID: 77953
Respondent: Bloor Homes Western
Agent: Marrons

Nothing chosen

No answer given

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Bloor Homes consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Birmingham’s unmet needs, this should include Stratford-upon-Avon given its rail links. As identified above, the Councils will be aware that Stratford–on-Avon District Council’s emerging Site Allocations Plan proposes reserving land east of Shipston Road for housing. This emerging allocation has been identified to help meet Birmingham’s unmet needs.

Form ID: 77963
Respondent: Bloor Homes Western
Agent: Marrons

Nothing chosen

No answer given

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Bloor Homes consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Birmingham’s unmet needs, this should include Stratford-upon-Avon given its rail links.

Form ID: 77966
Respondent: Mr O Farmer

No

As little scale as possible; it penalises those areas that have surpassed their targets .

Given the significant size of the shortfalls, developments should be focused on areas where higher number of dwellings can be built rather than focusing on small-scale piecemeal developments.