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?
Q-H4.1: The plan should take account of cross-boundary requirements prior to 2031 and beyond. It is unclear why the question specifies either ‘on identified sites’ or Stratford-on-Avon District alone. Q-H4.2: This should preferably be based on agreed outcomes arising from discussions by the authorities concerned. If there is no agreement, then past migration trends should be used as the basis for distributing any cross-boundary requirements.
In the past development capacity closer to the origin would have been emphasized. In the light of changing work patterns and a higher propensity to work from home a loosening of that approach might be more appropriate. It is also appropriate to bear in-mind that migration moves are made within the housing stock and not just new-build, so the existing stock can still enable migrants to live close to their point of origin should they wish to do so.
The emerging plan will have to play a role in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that Birmingham’s Issues and Options document identifies a housing shortfall of 78,415 dwellings. No reference is made to the extent of the housing shortfall arising from the Black Country. Following the abandonment of the Black Country Plan, the four Black Country authorities are producing individual Local Plans. However, the Preferred Options version of the abandoned draft Black Country Local Plan included a housing requirement shortfall figure that can be considered a credible starting point for considering the potential housing shortfall for the Black Country; a figure of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbations is 106,653 dwellings. The Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes could be provided within South Warwickshire to support the growth requirements of the Birmingham and Black Country conurbation. This is equivalent to under 5% to 10% of the total housing shortfall. It is entirely possible that the SWLP will be required to deliver numbers near the top end of this range. In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing need for Coventry should be significantly below the Standard Method housing requirement for the city, this has yet to be tested. The Draft Plan should, therefore, consider options for delivering additional housing to support for the growth of Coventry.
No answer given
The emerging plan will have to play a role in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that Birmingham’s Issues and Options document identifies a housing shortfall of 78,415 dwellings. No reference is made to the extent of the housing shortfall arising from the Black Country. Following the abandonment of the Black Country Plan, the four Black Country authorities are producing individual Local Plans. However, the Preferred Options version of the abandoned draft Black Country Local Plan included a housing requirement shortfall figure that can be considered a credible starting point for considering the potential housing shortfall for the Black Country; a figure of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbations is 106,653 dwellings. The Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes could be provided within South Warwickshire to support the growth requirements of the Birmingham and Black Country conurbation. This is equivalent to under 5% to 10% of the total housing shortfall. It is entirely possible that the SWLP will be required to deliver numbers near the top end of this range. In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing need for Coventry should be significantly below the Standard Method housing requirement for the city, this has yet to be tested. The Draft Plan should, therefore, consider options for delivering additional housing to support for the growth of Coventry.
No answer given
The emerging plan will have to play a role in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that Birmingham’s Issues and Options document identifies a housing shortfall of 78,415 dwellings. No reference is made to the extent of the housing shortfall arising from the Black Country. Following the abandonment of the Black Country Plan, the four Black Country authorities are producing individual Local Plans. However, the Preferred Options version of the abandoned draft Black Country Local Plan included a housing requirement shortfall figure that can be considered a credible starting point for considering the potential housing shortfall for the Black Country; a figure of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbations is 106,653 dwellings. The Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes could be provided within South Warwickshire to support the growth requirements of the Birmingham and Black Country conurbation. This is equivalent to under 5% to 10% of the total housing shortfall. It is entirely possible that the SWLP will be required to deliver numbers near the top end of this range. In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing need for Coventry should be significantly below the Standard Method housing requirement for the city, this has yet to be tested. The Draft Plan should, therefore, consider options for delivering additional housing to support for the growth of Coventry.
No answer given
Issue H4: Accommodating housing needs arising from outside of South Warwickshire 4.23 The Church Commissioners supports both Councils in recognising that they have a responsibility to contribute towards meeting unmet housing needs arising from within both Birmingham and Coventry. The Church Commissioners also supports the recognition that, even if the trendbased alternative approach to housing need is pursued, Coventry may not be able to accommodate all of its revised housing need (1,964 homes per annum.) Q-H4-2: In addition to the existing shortfalls identified for the period to 2031, Birmingham City Council has also commenced work on its Local Plan Review to 2042 and has recently published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes to 2042. Additional shortfalls may also be identified arising from the Black Country authorities, notwithstanding the cessation of the Black Country Core Strategy. 4.25 The Consultation Document identifies that, for the purposes of the accompanying Sustainability Appraisal, Stratford and Warwick District Councils have tested the effects of an additional 5,000 and 10,000 homes. 4.26 The Church Commissioners broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 4.27 Furthermore, it is important to note that this unmet need covers the period to 2042, whereas the South Warwickshire Local Plan is proposed to run to 2050. Any contribution towards this need made within the South Warwickshire Local Plan should accordingly be capable of being delivered within the required timeframe, and not left until the end of the South Warwickshire Local Plan period.
No answer given
The Parish Council recognise that South Warwickshire Local Plan has a duty to collaborate with the neighbouring authorities. The demand and need which comes from Birmingham and the Black Country is mainly for affordable homes. The problem of providing affordable homes in high land and house price areas has proved intractable nationally so that affordable and social housing numbers have declined sharply. The issues with the lack of social housing is due to Local Authorities not building any such housing, over a long period of time and which should be addressed.
The Parish Council question why should Warwickshire be catering for Birmingham issues when there are significant brownfield sites which should be developed for housing first, with in particular, affordable housing to meet the workforce needs of that area. Building on the green belt is a cheap option and irresponsible.
No answer given
Issue H4 – Accommodating Housing Needs Arising Outside of South Warwickshire 5.14.1 St. Modwen support the need to define the level of additional housing to allow the SWLP to proceed. Whilst the HEDNA looks at the Coventry and Warwickshire HMA area there is a significant under supply of 78,415 homes in the Birmingham City Council area that needs to be accommodated across the HMA. There is also additional under delivery in the Black Country area as well. 5.14.2 The only effective solution is for the SWLP Team to agree an acceptable contribution to this under delivery in the wider HMA areas. Failure to agree a position on accommodating additional housing risks significant future delays in any plan making process.
We agree that the Local Plan should contribute to meeting housing needs arising from outside South Warwickshire. Shortfalls should be accommodated in the most sustainable locations closest to the area from which the need derives. This may be within the Green Belt.
No answer given
WDC and SOADC should accommodate an appropriate proportion of the emerging GBBCHMA housing shortfall to 2040 and, once established, also accommodate an appropriate proportion of the emerging CWHMA housing shortfall. 3.40 Taylor Wimpey considers that the approach to the previous CWHMA shortfall up to 2031 was dealt with successfully through the preparation of a Memorandum of Understanding (MoU) agreed upon by each of the authorities. The MoU agreed the housing need for each authority between 2011 and 2031 and that an unmet need of 17,800 homes arose from Coventry. The MoU agreed how this unmet need was to be split between the seven authorities based on functional relationships, commuting patterns and the balance of jobs. This approach enabled all the LPAs within the CWHMA to progress their Local Plans, with the last plan adopted in June 2019. 3.41 In comparison, the approach to date by the GBBCHMA authorities has resulted in a substantial amount of Birmingham City Council’s shortfall identified in the 2017 Birmingham Development Plan (BDP) up to 2031, amounting to circa 6,000 homes remaining unaccounted for2 . Indeed, the current approach has impacted timescales for plan making elsewhere in the GBBCHMA. Since Birmingham’s Local Plan was adopted in 2017 only one authority within the GBBCHMA has adopted a plan identifying any housing to meet Birmingham’s unmet needs – North Warwickshire in September 2021. The certainty provided by a strategy agreed early on by all authorities will therefore ensure that plan making can continue without delay across the GBBCHMA. 3.42 This also needs to be considered in the context of unmet needs from other GBBCHMA authorities, including the Black Country. Although the Black Country Plan has now been abandoned, the most recent version of that plan established a shortfall of circa 28,000 homes up to 2039, this shortfall is robustly evidenced through the four councils’ Urban Capacity Study Update (December 2019) and tested through the West Midlands Combined Authority Brownfield Land Study. This shortfall is based on brownfield delivery and includes Green Belt release. If there were to be no Green Belt release, the unmet need would total circa 39,000 homes. 3.43 At this stage, Taylor Wimpey do not intend to propose a model for how any unmet needs should be distributed, this is for the SWLP and HMA authorities (both CWHMA and GBBCHMA) to determine in due course, following a number of matters being resolved in the first instance. The Association of Black Country Authorities (ABCA) letter to the wider GBBCHMA authorities on 26 April 2022 sets out a very useful starting point for the GBBCHMA authorities in order to commence preparing a SoCG and it is considered that this approach would be suitable for the CWHMA too: • Review the extent of the HMA in order to understand if it represents the most appropriate geography for considering unmet needs – this is pertinent given plans from outside the HMA (i.e., Shropshire and Stafford Borough) are offering contributions to the GBBCHMA’s unmet needs. • Confirm the scale of the housing shortfall across the entire HMA over a period of at least 15 years to inform the approach to be taken. This needs to consider the remaining unmet needs from other authorities, such as the Black Country, as it may be some of the unmet need has already been met by other GBBCHMA Councils. Review the 2018 Growth Study to understand if it remains appropriate and if there are new growth areas. This is likely to require a new study. • Review of governance arrangements between the GBBCHMA authorities in order to prepare a SoCG (an initial draft of which has been published as part of papers to Bromsgrove’s Full Council). 3.44 Whilst reviewing the 2018 Growth Study would be a useful part of any SoCG evidence base, this must be a fresh study that goes beyond the scope of the previous report and, similarly to the CWHMA and Leicester & Leicestershire HMA’s approaches, consider a model for distributing the unmet needs that goes beyond identifying growth areas. This must include detailed analysis and consideration of other models used by other HMA geographies for distributing unmet needs.
The overall contribution to any shortfall should be based on functional relationships, for example between Warwick district and Coventry, and between Stratford district and Birmingham. 3.46 Once this principle has been determined, growth should be distributed to the most sustainable locations within South Warwickshire. It is considered that by virtue of the functional relationships that exist at a strategic level, all key settlements and sustainable growth options will have strong links to the source of this shortfall.
Issue H4: Accommodating housing needs arising from outside of South Warwickshire 4.23 Caddick Land supports both Councils in recognising that they have a responsibility to contribute towards meeting unmet housing needs arising from within both Birmingham and Coventry. Caddick Land also supports the recognition that, even if the trend-based alternative approach to housing need is pursued, Coventry may not be able to accommodate all of its revised housing need (1,964 homes per annum). Q-H4-2: In addition to the existing shortfalls identified for the period to 2031, Birmingham City Council has also commenced work on its Local Plan Review to 2042 and has recently published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes to 2042. Additional shortfalls may also be identified arising from the Black Country authorities, notwithstanding the cessation of the Black Country Core Strategy. 4.25 The Consultation Document identifies that, for the purposes of the accomp anying Sustainability Appraisal, Stratford and Warwick District Councils have tested the effects of an additional 5,000 and 10,000 homes. 4.26 Caddick Land broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 4.27 Furthermore, it is important to note that this unmet need covers the period to 2042, whereas the South Warwickshire Local Plan is proposed to run to 2050. Any contribution towards this need made within the South Warwickshire Local Plan should accordingly be capable of being delivered within the required timeframe, and not left until the end of the South Warwickshire Local Plan period.
As acknowledged within the Consultation Document, there is a strong argument that, if homes are being provided to meet needs arising in Coventry and Birmingham, then those homes should be located as close as possible to the source of those needs in order to minimise travel. 4.29 As such, sites along the railway corridors and near the M40, as well as those with good connectivity to these locations, are likely to help accommodate unmet need from Birmingham and the Black Country, whilst sites south of Coventry can be identified and serve the wider housing shortfall of Coventry. However, these locations cannot then also serve local needs. Consequently, local need should be more evenly distributed across South Warwickshire, with proportionate growth delivered adjacent to existing settlements as part of an overall wider growth strategy. 4.31 Lastly, linked with our responses to Questions S3-1 and H1-1, the meeting of additional unmet need from neighbouring authorities is likely to necessitate the development of greenfield (and Green Belt) land.
No answer given
Issue H4: Accommodating housing needs arising from outside of South Warwickshire The Plan should clearly identify and reflect the current commitments included within existing adopted Local plan. This commitment be included/reflected as part of the current need in addition to any emerging need, and the approach used as part of the legal requirement in the Duty to Co-operate (as part of the wider GBBCHMA and CWHMA work) to continue in order to address future need
Q-H4-1: NWBC Response – Agree. This is an essential area of cross-boundary co-operation and an active element for the Duty to Co-operate. The Plan should clearly identify and reflect the current commitments included within existing adopted Local plan. This commitment be included/reflected as part of the current need in addition to any emerging need, and the approach used as part of the legal requirement in the Duty to Co-operate (as part of the wider GBBCHMA and CWHMA work) to continue in order to address future need Q-H4-2: NWBC Response – Base the accommodation on evidence of travel to work/commuting patterns to provide a true reflection of relationship with GBBCHMA. No further comment.
NWBC Response – Incorporate the shortfalls as an integral part of the Plans overall housing requirement, to be provided within the Plans overall settlement site allocations or similar. Advisable to avoid specific site allocations/identification to address the shortfall to be accommodated. No further comment.
The local plan needs to seek to accommodate some unmet need from the Birmingham and Black Country HMA. However, as noted in Q.H1.1, further evidence should be provided relating to migration within or between HMAs, particularly movements from Birmingham to more rural areas within South Warwickshire. The unmet needs arising from within Birmingham should be agreed via a Memorandum of Understanding and allocations made to meet the unmet needs within Part 1 of the Local Plan dealing with strategic policies. If homes are being provided to meet needs arising in Coventry and Birmingham then those homes should be located as close as possible to the source of those needs in order to minimise travel, or close to good transport connections to these areas. Particular emphasis should be placed on locations for development to service the needs of Birmingham and Coventry that have sustainable connections to these cities. If South Warwickshire are to accept a substantial shortfall arising from within Birmingham and the Black Country, then there should be an expectation that those local authorities have accommodated growth within the Green Belt falling within their own administrative areas.
Additional housing to meet the shortfalls from neighbouring authorities should be located on public transport corridors, i.e. Growth Options 1 (rail corridors) and 2 (sustainable travel) in order that residents of the new housing can utilise existing sustainable transport options to commute to work. The Greater Birmingham HMA (GL Hearn, 2018) includes three sites within Stratford-on-Avon within its area of search for potential sites, one of which is directly related to Stratford-upon-Avon. In consideration of the rail infrastructure between Stratford-upon-Avon and Birmingham City, the site a Copham’s Hill, Stratford-upon-Avon, is one such site that can deliver sustainable housing that would contribute to the shortfalls.
3.49 RPS welcomes the reference made in the SWLP potential requirement to meet identified housing shortfall from neighbouring authorities. The SWLP recognises that the SW area sits in the wider West Midlands region, and in preparing the SWLP it will be necessary to take into account the plans and strategies of a number of neighbouring authorities. RPS contends that this represents a key strategic matter that will need to be addressed through the SWLP as it moves forward, as part of the Duty to Cooperate obligations relevant to the SWLP, which the LPAs recognise is required (page 101). 3.50 Whilst RPS acknowledges that the Government has proposed reforms to the NPPF (with consultation running up to 2nd March 2023), looks to propose removal of the Duty to Cooperate until provisions come into effect and it be replaced with an “alignment policy” as part of a future revised NPPF. As yet, however, it is not clear what specific requirement will replace the duty. Nonetheless, there remains the requirement in national policy for strategic policies to address strategic priorities of the area, including any relevant cross-boundary issues and also the requirement to demonstrate effective and on-going joint working by documenting those relevant cross-boundary matters that are being addressed and the progress made in cooperating to address these. 3.51 Page 111 of the I&O consultation document refers to the four elements of unmet need that may have implications for South Warwickshire arising from the different Housing Market Areas. These HMAs are likely to face difficulties in meeting their own needs within their boundaries as time moves on, given that both Birmingham and Coventry are now amongst the ‘35% uplift’ authorities identified as part of the revised standard method. Birmingham City Council’s Local Plan review to 2042 has an identified housing shortfall of 78,415 homes. 3.52 Based on the information set out in Chapter 6 regarding shortfalls, the SWLP provides no clarity on how much potential housing shortfall from the surrounding HMAs that would be addressed in the SWLP, apart from highlighting two potential contributions of 5,000 and 10,000 additional homes in the Sustainability Appraisal. The SWLP should under a separate policy to make a commitment to accommodating a proportion of any identified housing shortfall from its neighbours and build this into the emerging spatial strategy for the SWLP. 3.53 There are, in addition, other local authority areas that are also likely to face their own challenges in meeting their housing need once their plans are brought forward for review. Based on current available information these are likely to include the Black Country Authorities, and potentially in neighbouring Redditch and Bromsgrove who may be requested to take some of this housing shortfall. These areas share the same housing market area with Stratford-upon-Avon. 3.54 In the Black Country, it is now apparent that there will be an identified housing shortfall post 2031 in the GBBCHMA, with the Black Country Urban Capacity Review estimated a shortfall of 29,288 dwellings4 by 2038 (paragraph 2.1.40), which it will be the primary issue for consideration through the respective emerging Local Plans (given the now defunct joint Black Country Plan). This represents a substantial level of unmet need, which does not take into account the 35% uplift that will also need to be applied to Wolverhampton’s component of the Black Country’s need, which is likely to further increase the scale of the shortfall. More recent evidence5 indicates that the shortfall in the Black Country has increased further, from 29,288 to 36,819 dwellings, an increase of over 25% on previous estimates. 4 Black Country Urban Capacity Review December 2019 3.55 RPS would recommend that a key consideration in identifying suitable locations to address these shortfalls should be to prioritise locations that are accessible and in close proximity to where the unmet need arises, thus reducing travel distances as well as offering the potential for linked service provision to meet the wider needs of the new communities. In strategic terms, this means that the re-distribution of any unmet housing need should be related to settlements on a duty to cooperate basis (in this instance South of Coventry), and which would clearly lead to an increase in the overall level of growth to be accommodated within the SWLP and the need for additional land to accommodate that growth.
3.56 The Warwick District of the Coventry and Warwickshire HMA most strongly relates to Coventry given its shared boundary and interrelationships with the city. Under the trend projection put forward in the HEDNA, the redistribution of housing resulting from this, it is likely Coventry will not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. Recognising that these shortfalls arise because of the way Coventry is constrained by the West Midlands Green Belt. However, consideration must be given to the strength of the relationship between South Warwickshire and the source of these shortfalls. RPS considers that the significant scale of the shortfalls presents exceptional circumstances that justify the release of land from the Green Belt for residential development. 3.57 The Green Belt areas in sustainable areas, in proximity to where the strength of the relationship from where shortfalls arise is strongest, areas south of Coventry are considered to be the most appropriate locations for sustainable urban extensions to accommodate this need. 3.58 This view is reaffirmed by the Council, RPS are aware that Warwick District Council, alongside partners Warwickshire County Council, Coventry City Council and the University of Warwick, are undertaking a masterplanning framework for land to the north of Kenilworth/south of Coventry area. Further information is available in the Cabinet Report from April 2022. The Cabinet Report states: 3.59 “There is considerable growth pressure in this area, and this can be seen in sites that are already being promoted in the South Warwickshire Local Plan (SWLP) being prepared jointly by Warwick and Stratford District Councils”. 5 The Black Country Urban Capacity Review Update (May 2021) Summary, page 2