Issue and Options 2023

9. Land at Walton Road, Wellesbourne 9.1. Rainier Developments is promoting land at Walton Road, Wellesbourne for residential development, inclusive of on-site green infrastructure. 9.2. The land comprises of an agricultural field, with associated agricultural buildings in the north-western corner and an existing access via Walton Road located close to the buildings. The site is located in between two new residential development, both built out by Persimmon. The site to the north-west (known as Ettington Park) is complete and occupied. The site to the south (known as The Grange) is continuing to be constructed and is partially occupied. 9.3. It is clear that these residential developments have changed the character of this part of Wellesbourne which is now typified by modern residential development. The development of this site would form part of this context and would effectively round off the settlement in this location. Walton Road forms a clear boundary for development in this area. The land beyond Walton Road is constrained by the River Dene and is unlikely to be suitable for large-scale development. 9.4. The accompanying Illustrative Masterplan (please see Appendix 3) shows how the site could accommodate circa 65 dwellings. This shows how the majority of the existing boundary vegetation could be retained and enhanced. The masterplan shows on-site open space located to link with the public open space on the adjacent housing developments. Access is proposed via Walton Road and a technical note has previously been prepared and submitted (please see Appendix 4) which confirms a suitable access arrangement can be achieved. Sustainability Appraisal SA 9.5. This site is located in the small settlement of Wellesbourne, as shown on Figure C.19.1. The site appears to fall between the area identified as the built-up boundary and the small settlement boundary (identified by a brown outline) on this figure. The site adjoins the built-up boundary and should clearly be considered as part of any housing growth in Wellesbourne. 9.6. The assessment of Wellesbourne against the SA objectives is presented at Section C19.1 of Appendix C. It is acknowledged that, at this stage, the assessment covers a wide area and the ratings will not be applicable to each site within the settlement. Each SA Objective is considered with specific reference to the site below: 9.7. SA Objective 1 Climate Change: The site would deliver circa 65 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support the delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs as it would benefit from access to existing service and facilities in Wellesbourne. 9.8. SA Objective 2 Flood Risk: The site is entirely within Flood Zone 1, land at lowest risk of flooding. There are areas of surface water flood risk, predominantly parallel with Walton Road however this could be addressed by suitable design and sustainable drainage systems. It should be noted that much of the undeveloped land, particularly in the north of Wellesbourne, is constrained by flood risk with significant areas of flood zones 2 and 3 present, associated with the River Dene and River Avon. 9.9. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: The site is not designated as or in close proximity of a Special Conservation Area (SAC), Site of Special Scientific Interest (SSSI), National Nature Reserve (NNR), ancient woodland, Local Nature Reserve, Local Wildlife Site, Local Green Space (LGS) or priority habitat. It is acknowledged that the site is within the Impact Risk Zone for Loxley Church Meadow SSSI however this could be addressed by suitable mitigation. 9.10. SA Objective 4 Landscape: The site is characterised by modern residential development on two sides. The Ettington Park development adjoins Walton Road, as does The Oaks, a small office development which immediately adjoins the site. The Grange locates the open space towards Walton Road however this development is to the south of this Site, beyond the Grange is agricultural fields. The Site would continue the existing build line along Walton Road as established by Ettington Park and The Oaks. The Illustrative Masterplan (enclosed at Appendix 3) shows how the site could be designed with on-site open space to link in the open space provided by the Grange. This would create a coherent development and minimise any landscape impacts through good design. A landscape note has previously been prepared for this site and submitted to the Council (see Appendix 5). This Note concluded that the site benefits from total enclosure on three sides with only the eastern aspect towards the River Dene where sensitively designed buildings which reflect the local character can create an attractive settlement edge. 9.11. SA Objective 5 Cultural Heritage: The site is not located in proximity to any designated heritage assets. The listed buildings and Conservation Area are concentrated around Bridge Street/Ettington Road, to the north-west of the site and separated by existing development. The scheduled monument and registered park and garden referred to by the SA are located north-east of Wellesbourne and are a significant distance from this Site. 9.12. SA Objective 6 Pollution: The site is not located in proximity of an Air Quality Management Area (AQMA). The SA refers to the A429 as a potential pollution source. The Site is separated from the A429 by existing modern residential development so it is reasonable to conclude that any mitigation required for noise and air quality would be minimal and achievable. 9.13. SA Objective 7 Natural Resources: It is acknowledged that the Site would result in a loss of agricultural land however this would be a minor loss due to the relatively small site size. The Site is within a Mineral Safeguarding Area (MSA) however the site is relatively small compared to the MSA and given the location of adjacent residential development mineral extraction is unlikely to be acceptable in terms of residential amenity. 9.14. SA Objective 8 Waste: A development of circa 65 houses would generate a level of household waste however this can be managed with provision of suitable recycling facilities for all households. 9.15. SA Objective 9 Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing. 9.16. SA Objective 10 Health: The site benefits from frequent bus services on Ettington Road which provides frequent services to Warwick, Leamington Spa and Stratford-upon-Avon and access to hospitals. Wellesbourne benefits from a recently developed doctors surgery located within a mile of this Site. There is also good access to leisure and recreation facilities within Wellesbourne with scope to provide on-site open space and connections to the public open space being provided by the Grange. 9.17. SA Objective 11 Accessibility and 12 Education: The site benefits from existing bus stops on Ettington Road and frequent local services to Leamington Spa, Warwick and Stratford-upon-Avon. These locations have train stations for onwards journeys, including to Birmingham. There are also various local services and facilities within the local area, including a primary school. The secondary schools in Stratford-upon-Avon would also be accessible using public transport. 9.18. SA Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with Wellesbourne which include the Distribution Park and the Wellesbourne Campus of the University of Warwick. Summary 9.19. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.20. The Vision Document indicates how a scheme of circa 65 dwellings can be achieved having regard to the site constraints and opportunities. 9.21. The site benefits from a highly sustainable location within Wellesbourne and is well placed to meet the housing needs of the area. The site is well-placed to ensure easy access to a range of services and facilities including public transport. 9.22. The Illustrative Masterplan shows how the site would follow the existing building line along Walton Road as established by the developments to the north-west and provide on-site open space which would link to the public open space on the site to the south (known as the Grange) to provide a coherent development which rounds off this part of Wellesbourne. 9.23. The site is not subject to any statutory nature or heritage designations. The site is entirely within Flood Zone 1 which represents the lowest risk of flooding. The Site could deliver sustainable drainage systems (SuDS) as part of any development. 9.24. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.25. Rainier have a land interest in the Site and are promoting the site for residential development. The Site has already been submitted as part of the Call for Sites exercise associated with the Scoping Consultation in 2021, and accompanying representations were also submitted. 9.26. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.27. Rainier’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation and previous representations throughout the preparation of the South Warwickshire Local Plan. 9.28. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.29. Rainier have a land interest in this Site and are actively promoting the Site for residential development. The site is immediately available and could deliver housing in the early part of the Plan period.

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2.1. As set out in response to the Scoping and Call for Sites consultation, Rainier supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. 2.2. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a much more rural population than Warwick and those differences must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making 2.3. Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Rainier supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. The plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented, which accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” 2.5. The five overarching principles which then set out the basis on which policies will be formed and thus how the Vision will be delivered, do not match the Vision as drafted. For example, the delivery of ‘homes and jobs’ does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation documents goes onto talk about the delivery of growth, an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. 2.6. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported, and it aligns with the Government’s aspirations for achieving net zero carbon emissions, it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. 2.7. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle, and it is acknowledged that national policy is pursuing ‘beauty’ in planning however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options the SA consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported however it is recognised that at this stage, the SA considers wide areas and therefore the assessments will not apply to each site within these areas equally. As the Plan progresses it will be necessary to undertake more fine-grained, site-based analysis. Further comments are made below and in following sections regarding the sites suitability for development when considered against the SA objectives.

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Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.

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3.20. Shipston-on-Stour is subject to a single assessment for the purposes of the Settlement Design Analysis which forms part of the Council’s evidence. The site is within Parcel 6. It scores a C in terms of accessibility (amber) which is the joint highest score within this analysis area. The land to the north-west of the site is highlighted in terms of its topography, associated with Waddon Hill. It has places to meet, open space, leisure, recreation and wellbeing, healthcare and education within 800m of the site. The density map notes that the site is opposite an industrial area. The site is also adjacent to the leisure centre and school and it is suggested that the map could helpfully be updated to include a recreation/education item in the key.

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Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 3.12. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.13. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.14. Growth at existing settlements across the Joint Plan area should form part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. 3.15. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.16. In order to develop the most sustainable pattern of development, growth at existing settlements should be in sustainable locations. It is important that appropriate levels of growth are apportioned to existing settlements in order to maintain the vitality and viability of settlements, support new and existing infrastructure requirements and provide an appropriate mix of housing for the area. 3.17. Shipston-on-Stour is identified as a town and as such is a sustainable location for development. This Site would allow for a sustainable development close to existing services and public transport. 3.18. As set out in the Sustainability Appraisal, the site is within Broad Location ‘Shipston-on-Stour North’ which the SA shows is the second best performing Broad Location in terms of environmental receptors (see Table at 4.10.1). Shipston-on-Stour North performed best in terms of accessibility, education and economy. 3.19. It is clear that this Site (Call for Sites ref: 460) is located in an entirely sustainable location and should be positively considered as a location for growth. Issues S6: A Review of Green Belt boundaries 3.21. The Issues and Options consultation document does not set out any specific question on Green Belt matters, but these representations support a review of the Green Belt boundary as part of the Plan making process. 3.22. As set out in the NPPF para 136, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of Local Plans. Moreover, strategic policies should establish the need for changes to Green Belt, and where proposed, the amended boundaries should be able to endure in the long term, i.e. Green Belt boundaries will not need to be altered at the end of the plan period. 3.23. NPPF para 137 requires exceptional circumstances to include evidence of the examination of all other reasonable options for meeting an identified need for development. Importantly, in reviewing Green Belt boundaries sustainable patterns of development should be taken into account. 3.24. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and review growth options, where the most sustainable form of development is likely to be around existing settlements, it is therefore imperative that the Local Plan evidence base includes a Green Belt review. The Councils’ recognition of this in relation to a number of the proposed growth options is supported. 3.25. If a Green Belt boundary review is not undertaken, development will need to ‘jump the Green Belt’ which would result in an isolated pattern of development. Q-S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 3.26. It is noted that the Issues & Options document has reduced the previous seven growth options presented in the Scoping Consultation to five options as outlined above through refining and combining options, including Option 2 sustainable travel (combination of rail and bus corridor) and Option 3 economy (combination of socio-economic and enterprise hub options). In this consultation document, Option 4 sustainable travel and economy effectively combines Options 2 and 3. It is clear from this process that the growth option to be pursued will represent a combination of all five options outlined above. 3.27. The options now presented in the Issues and Options, apart from Option 5: Dispersed, perform broadly similarly to each other in the SA (Table 7.1) suggesting not one option may have significantly more or less impact than any of the others when considered against the SA Framework. At this stage, the SA has not considered any mitigation or site-specific options for growth within settlements identified within the ‘dispersed’ option (5). There could be significant variance in how each settlement and individual sites would perform against the SA objectives. All of the growth options could deliver sustainable development and a combination of all options will be the most appropriate option for the development of the Plan going forward. 3.28. By necessity, the strategy will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66 year supply of housing. Land from other sources will therefore be required and it is important that all options are considered in taking the Plan forward. 3.29. Combining sustainable travel (including rail) and economy will naturally direct most growth to the larger, more sustainable settlements. However, it is important that appropriate, proportionate growth is directed to smaller settlements in order to support the continued viability and vitality of these settlements going forward. This would include supporting or enhancing sustainable travel options at these locations. This needs to be positively planned for as part of the South Warwickshire Local Plan and as such an element of dispersal should form part of the final growth option. This will require a careful consideration of all of the options, including growth at existing main settlements, growth at smaller existing settlements, proximity to services and jobs, availability of infrastructure or opportunities for infrastructure delivery and a Green Belt boundary review to ensure development is not isolated beyond the defined Green Belt boundaries. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Q-S8.2 For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 3.30. The supporting text for this question confirms that the aim of this approach would be to allow for development within or adjacent to existing settlements. This provides greater scope of these settlements to accommodate growth than the current infill only approach. The proposed approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. 3.31. An across the board threshold limit of 10 dwellings is not supported. The amount of development different settlements can accommodate will vary significantly depending on various factors, such as existing services and facilities, local need for housing and the suitability of the proposed site to accommodate a certain level of development. 3.32. In addition, developments of 10 or fewer dwellings are exempt from affordable housing. Even where a lower threshold is set, developments of this scale generally result in a commuted sum towards affordable housing elsewhere. This is due to a variety of factors, including that registered providers often will not take on a small number of dwellings in one location. It is clearly preferable to have affordable housing delivered on site wherever possible to meet local needs. Setting a more flexible threshold that would allow for a higher level of development where appropriate would support greater on-site affordable housing provision. Q-S9: Please select the option which is most appropriate for South Warwickshire 3.33. The South Warwickshire Local Plan provides the opportunity to review all settlement boundaries and ensure they will be fit for purpose across the plan period. Saving all existing settlement boundaries is unlikely to be effective in positively planning for plan-led growth across the plan period. This should apply all settlements as part of the exercise will be to assess which settlements which would benefit from a defined boundary. 3.34. To be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. 3.35. In addition, settlement boundaries will need to be reviewed and amended to take account of new allocations. 3.36. For example, development boundary for Shipston-on-Stour should be reviewed which would allow for the inclusion of this Site (Call for Sites ref: 460) within the development boundary to deliver sustainable residential growth.

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4.1. Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of “significantly boosting” the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. 4.2. The Planning Practice Guidance (PPG) (paragraph 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. 4.3. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Hosing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the Joint Plan area. 4.4. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle. The trend based figures, which equate to an overall housing need across the Joint Plan area of 1,679 dwellings per annum is supported in principle. 4.5. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. 4.6. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now, and will continue to exist in the future. 4.7. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix 1) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear.” 4.8. It is important to stress that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted Birmingham Development Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed into the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further.