Issue and Options 2023

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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 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. 3.32 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 for1. 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. 3.33 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. 3.34 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). 3.35 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 1 https://www.birmingham.gov.uk/downloads/file/21347/gbbchma_position_statement_adden dum_2019_to_2020_17_december_2021 10 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 between Warwick district and Coventry, and between Stratford district and Birmingham. 3.37 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.

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3.38 Climate change adaptation and climate change mitigation are core threads of the NPPF via the delivery of sustainable development. 3.39 In this context, the five overarching principles of the SWLP are welcomed and supported, in particular those that relate to climate resilience, net zero, biodiversity and environmental resilience in South Warwickshire. 3.40 Taylor Wimpey published its Environment Strategy (Appendix 2) in 2021 which established objectives and targets for climate change, nature, resource consumption and waste generation up to 2030 on new developments. 3.41 The Environmental Strategy aligns with the emerging vision, objectives and principles for the SWLP and in summary Taylor Wimpey is committed to the following targets: (i) Reduce operational carbon emissions intensity by 36% by 2025 from a 2019 baseline. (ii) Reduce carbon emissions intensity from its supply chain and customer homes by 24% by 2030 from a 2019 baseline. (iii) Increase natural habitat by 10% on new sites from 2023 and include priority wildlife enhancements from 2021. (iv) Cut waste intensity by 15% by 2025 and use more recycled materials. 3.42 Taylor Wimpey has formed several partnerships with nature organisations including Hedgehog Street and Buglife to protect and enhance natural habitats in new neighbourhoods. 3.43 It is recommended that the site selection process is informed by those strategic sites which can provide climate change adaptation and climate change mitigation as 11 referred to in National Planning Practice Guidance (PPG) [Paragraph 003 Reference ID: 6-003-20140612 and Paragraph 007 Reference ID: 6-007-20140306].

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3.44 Option C9.1a is the most appropriate option for South Warwickshire and is in accordance with paragraphs 177d and 182b of the NPPF which seek to secure biodiversity net gain via plan-making. 3.45 However, any planning policy requiring new development to incorporate measures to increase biodiversity should be flexible and adhere to the PPG [Paragraph 022 Reference ID: 8-022-20190721] which states, “biodiversity net gain can be achieved onsite, off-site or through a combination of on-site and off-site measures”. 3.46 It is recommended WDC and SOADC work with Warwickshire County Council (WCC) to identify ‘habitat banks’ i.e. areas of enhanced or created habitats which generate biodiversity credits. This will support strategic sites that are unable to deliver net gain wholly on site.

3.47 As explained in the Issues & Options, it is agreed that public open space is not a strategic priority to address in the SWLP Part 1. 3.48 Taylor Wimpey welcome further engagement on the “further evidence” to be collated to determine the level of public open space need in South Warwickshire. 3.49 Finally, it is agreed that public open space requirements will change over time and it is important for any non-strategic policy to be flexible to reflect any such changes to need.

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3.50 Taylor Wimpey is generally supportive of the inclusion of guidance in respect of 20- minute neighbourhood principles in the SWLP. Such principles will guide proposals for a new neighbourhood at Hockley Heath. However, this should not be a policy requirement as the composition and functionality of a neighbourhood is in constant flux. 3.51 Taylor Wimpey therefore support Option T1b, but these must refer to and reflect the principles that are already established in the NPPF, PPG, the National Design Guide, which should inform and guide the SWLP. 3.52 Whilst the NPPF does not refer directly to 20-minute neighbourhoods, the SWLP will need to be consistent with national policy to enable the delivery of sustainable development – therefore by virtue of the test of soundness, the SWLP will embed the principles of 20-minute neighbourhoods in its strategic and non-strategic policies.