Issue and Options 2023

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Question S9: 3.20 IM consider that the Part 1 Plan should review and re-assess all settlement boundaries to consider the most sustainable pattern for housing growth, including the land south of Coventry. This will require the removal of land from the Green Belt, and is therefore a strategic matter for consideration within the Part 1 Plan.

3.21 IM generally support the broad vision and strategic objectives for the distribution of development set out in the Issues and Options document. However, to meet this vision, it is important to ensure that growth is distributed towards the most sustainable locations. When considering the proposed growth options 2 (Sustainable Travel) and 3 (Economy), the most appropriate locations for growth are those adjacent to existing urban areas, such as the land directly to the south of Coventry, where facilities and connections are already available, which includes the currently safeguarded land off Westwood Heath Road. 3.22 Sites which are safeguarded in the adopted WDC Local Plan (Adopted 2017) have already been determined by an inspector to be suitable for future sustainable development potential and therefore removed from the Green Belt. The safeguarded land at Westwood Heath Road, should be allocated through the SWLP to ensure a pipeline of housing sites and enable the delivery of new homes in the early stages of the plan period. 3.23 The findings of the Sustainability Appraisal prepared in support of the adopted WDC Local Plan (2017) supported and resulted in the allocation of the Site as a safeguarded site within the plan. This clearly supports the Site as a sustainable location for growth and should therefore be recognised and referenced through the updated evidence-based documents for the SWLP. It is also considered that the Sustainability Appraisal for the SWLP should account for sufficient mitigation, in order to accurately identify the most appropriate options. 3.24 Further growth to the south of Coventry is also clearly supported through WCC and WDC’s work to create a masterplan for this area, as detailed in the introduction section of these representations. Therefore, to support the ongoing masterplanning work and ensure consistency between the Councils’ workstreams, the allocation of the Site through the SWLP represents a sensible and logical approach.

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Question H1.1: 3.25 IM 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. 3.26 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.

3.27 IM considers that there is an opportunity to increase the overall housing requirement for the plan period to help deliver a higher amount of affordable housing. Table 8.45 of the HEDNA states that WDC and SDC have a combined affordable annual need of 1,386 dwellings per year, this is a significant need and would justify a higher overall housing requirement to ensure that sufficient affordable homes are being provided throughout the plan period. 3.28 It is also relevant to note that constraints on the release of land for residential development, and in turn the provision of houses on that land (for sale or as affordable provision), can lead to increased house prices in an area. The Plan should therefore be focused on creating a policy environment that does not place undue constraints on sites that are allocated, thereby maintaining a supply that will in turn address issues of affordability.

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Question H3a: Do not seek to include minimum space standards in a policy in the SWLP. 3.29 Space standards are not a strategic matter and should therefore be dealt with in any Part 2 Plan. As set out in Paragraph 002 of the NPPG Chapter ‘Housing: optional technical standards’, any proposed space standards will need to be sufficiently evidenced, to justify a local need for exceeding the minimum standards required by Building Regulations and an optional nationally described space standard.

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3.30 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. 3.31 IM consider that 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. 3.32 The CWHMA approach has been much more successful in ensuring the identified shortfall has been met, when compared to the Birmingham City Council (BCC) shortfall UP TO 2031 which was identified in the 2017 Birmingham Development Plan (BDP). The approach to date by the GBBCHMA authorities has resulted in a substantial amount of BCC’s shortfall identified in the 2017 BDP, amounting to circa 6,000 homes remaining unaccounted for. The GBBCHMA approach has impacted timescales for plan making elsewhere in the MA. Since Birmingham’s 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 and CWHMA. 3.33 This also needs to be considered in the context of unmet needs from other HMA 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 WMCA Brownfield Land Study. 3.34 IM consider that 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: • Reviewing 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. • Reviewing 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). 3.35 Whilst reviewing the 2018 Growth Study would be a useful part of any SoCG evidence base, we are of the view this must be a fresh study that goes beyond the scope of the previous report and, similarly to the previous CWHMA approach, 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.

3.36 The overall contribution to any shortfall should be based on functional relationships, for example with WDC and Coventry, and between Stratford and Birmingham. Once this principle has been determined, growth should then be located in the most sustainable locations within WDC and SDC. 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.

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Question H5: 3.37 There are significant difficulties associated with setting a standard proportion of self and custom-build homes for all large-scale sites, due to the scale of housing development that is often required, and the diversity of housing needs and demographics between different local areas. IM considers that this approach would be more appropriate to smaller scales sites and could therefore be dealt with through the Part 2 Plans or neighbourhood planning.