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ID sylw: 108184

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

2.1 The National Planning Policy Framework (2024) [NPPF] sets out the Government’s
framework within which locally prepared plans can provide for sufficient housing and other
development in a sustainable manner (Para 1). It goes on to state that:
“The planning system should be genuinely plan-led. Succinct and up-to-date plans should
provide a positive vision for the future of each area; a framework for meeting housing
needs and addressing other economic, social and environmental priorities; and a
platform for local people to shape their surroundings.” (Para 15) (Emphasis Added)
2.2 In this regard, the PO sets out the SWA’s proposed Vision for South Warwickshire over the
plan period, alongside Strategic Objectives and how individual policies will contribute
towards addressing the Vision. In general, St Philips broadly support the SWA’s proposed
Vision and Strategic Objectives, as they align with the key tenets of sustainable
development in the NPPF.
2.3 However, St Philips is disappointed to see that the SWAs have omitted the previous
reference to addressing the unmet housing needs of neighbouring authorities from the
Vision, which was set out in the Issues and Options [IO] consultation. The NPPF is clear
that planning policies should as a minimum, provide for objectively assessed needs for
housing and other uses, as well as any needs that cannot be met within neighbouring areas
(Para 11b) (i.e. meet their own needs in full, and any other unmet needs from neighbouring
authorities). Furthermore, paragraph 24 reemphasises that local planning authorities
[LPAs] continue to be under a duty to cooperate [DtC].
2.4 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). Crucially, as the
Vision and Strategic Objectives inform the policies within the SWLP, for the SWLP to be
‘positively prepared’ both the Vision and Strategic Objectives should set out a positive
approach to addressing unmet housing needs.
2.5 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 need to make provision for
these needs in part. At present, St Philips considers that the Vision does not place much
emphasis – or any at all – on contributing towards addressing the housing shortfall
challenges within GBBCHMA, despite a requirement under the NPPF to seek to address
them. To ensure the SWLP sets out a positive Vision, St Philips considers it should make
reference to the SWLP’s role in addressing this critical cross-boundary issue.
2.6 Equally, 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 these critical crossboundary issues, or as a Strategic Objective in its own right.