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ID sylw: 107891

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

The PO sets out the SWA’s proposed Vision for South Warwickshire over the plan period to
2050. It considers options for a planning policy response to ensure that it is able to meet
spatial planning and development needs and how individual policies will contribute
towards addressing the Vision. Terra broadly support the SWA’s proposed Vision and
Strategic Objectives, as they align with the key tenets of sustainable development in the
NPPF.
2.2 Terra is concerned that the SWAs have omitted the previous reference to addressing the
unmet housing needs of neighbouring authorities from the Vision and which was previously
set out in the Issues and Options [IO] consultation. The NPPF is clear that planning policies
should provide for objectively assessed needs for housing and other uses, as well as any
needs that cannot be met within neighbouring areas (Para 11b) In this respect, paragraph
24 emphasises that; “Local planning authorities and county councils (in two-tier areas)
continue to be under a duty to cooperate with each other, and with other prescribed
bodies, on strategic matters that cross administrative boundaries.”
2.3 The NPPF is clear that for a Local Plan to be found sound, it must be ‘positively prepared’,
which means that it must provide a “strategy which, as a minimum, seeks to meet the
area’s objectively assessed needs; and is informed by agreements with other authorities,
so that unmet need from neighbouring areas is accommodated where it is practical to do
so and is consistent with achieving sustainable development” (Para 35a). Therefore, for the
SWLP to be ‘positively prepared’ both the Vision and Strategic Objectives and land use
policies and housing allocations should set out a positive approach to addressing unmet
housing needs.
2.4 In light of the above, and as discussed in detail below, there is a large quantum of unmet
housing needs arising in the Greater Birmingham and Black Country Housing Market Area
[GBBCHMA] which the SWAs are part of. The SWLP will consequently need to consider
whether it should make provision for these needs in part. At present, Terra considers that
the Vision does not effectively address the housing shortfall challenges within GBBCHMA,
despite a requirement under the NPPF to meet the Duty to Co-operate (DtC).
2.5 Strategic Objective 2 (Delivering homes that meet the needs of all our communities) does
not include any reference to addressing the unmet housing needs of neighbouring
authorities. Whilst it is noted that PO does, in Draft Policy Direction 4 (Accommodating
Growth Needs Arising from Outside South Warwickshire), acknowledge that the SWLP may
need to assist in meeting these unmet housing needs, it fails to recognise the acuteness and
seriousness of this situation in Strategic Objective 2. Again, Strategic Objective 2 should
refer to the SWLP’s role in addressing this critical cross-boundary issues, or as a Strategic
Objective in its own right.