The South Warks Local Plan Consultation is asking the wrong questions!

“We appreciate Warwick and Stratford District Councils consulting about future housing needs in our towns and villages. But only asking where we want 35,000 new houses by 2050, not whether we need them, is posing the wrong question.”

That’s why CPRE Warwickshire commissioned an independent Report from planning specialist, Gerald Kells, who has already reviewed Birmingham, Leicester, and the Black Country’s housing needs estimates. His report highlights major flaws in the assumptions underpinning the Local Plan. Each one of these increases housing numbers – and demand for land to build them on – exponentially.

The first and biggest flawed assumption is about ‘Windfall Sites’. This is land, often brownfield, that becomes available during a plan’s lifetime but is not known about at the start. The SWLP assumes enough land will come vacant between now and 2050 to build 220 homes each year. Since 2011, the average windfall space has been more than four times that – enough for 901 homes. Prudence is one thing. But this 220 seems to fly in the face of reality.

If the two local authorities are ultra-cautious and only assume half the average number of windfalls will come vacant between now and 2050, the housing land shortfall drops to extra space being needed for just 9,310 homes by 2050. Not 35,000. If the assumption is that there will be roughly the same number of windfall sites as there have been since 2011, we are already in land surplus! – 5,255 excess house spaces available in 2040; 3610 in 2045 and 1965 in 2050.

Map of potential development sites as part of the South Warwickshire merger

The second flawed assumption, according to Gerald, is to apply an ‘affordability uplift’ to actual confirmed housing need, as expressed in ONS and Census data. This is an economic theory, discredited since 2004 (but still in use by some local authorities). It states that if you build more houses, prices will tumble. South Warwickshire’s confirmed need is for 874 homes pa. Using the affordability uplift, 874 homes becomes 1,239. This is an increase over and above actual need of 42%. The third flaw is that under the local authority ‘Duty to Cooperate’ South Warwickshire has had to provide land and housing to meet Coventry’s past assumption of a 32% growth in population. In fact, independent ONS figures show 17,000-18,500 fewer households than Coventry assumed. So the excess housing that had to be built in South Warwickshire under the Duty to Cooperate, has led to massive in-migration from elsewhere in the area – not homes for local people. Stratford has provided 118% of its actual local need. 76% of Warwick’s growth has come from in-migration.

Under the SWLP to 2050, there is a clear danger that our areas will be obliged to provide housing and land to meet a statutory Birmingham housing requirement that is three times the City’s actual demographic need. So that’s potentially homes that Warwickshire doesn’t need, to meet a Birmingham shortage that doesn’t exist. The final factor leading to unrealistic numbers is the decision to extend the SWLP plan horizon to 2050, not 2040. (15 years is more usual.) Of course, it’s important for local authorities to have time to plan infrastructure and utility needs. But can Warwick and Stratford seriously say – hand on heart – that they know housing needs and likely land availability for the next 27 years? Covid destroyed even five-year plans. Extending the South Warwickshire plan to 2050, increases housing numbers and the land grab by 50%. (35,000 homes by 2050, not 23,370 by 2040.)

We believe that these assumptions are seriously flawed. That’s why we are respectfully asking those responsible to reconsider the base assumptions underpinning the South Warwickshire Local Plan. They need to take Gerald Kells’ forty pages of detailed statistical evidence seriously. Otherwise, more farmland and greenbelt will be destroyed, to meet a non-existent housing shortage.

Judith Cobham-Lowe, Chair, CPRE Warwickshire

At the time of writing and before printing the joint Local Plan proposal is live. It remains to be seen whether the changes in the political landscape of Warwick and Stratford upon Avon following the recent local elections result in ‘more of the same’ or something different.