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ID sylw: 108361

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

generally, Mackenzie Miller Homes considers that the Vision and Strategic
Objectives are acceptable, more consideration and clarity are needed with respect to current
housing needs and unmet housing needs from the neighbouring authorities. The National
Planning Policy Framework (2024) [NPPF] states 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 Therefore in this regard, Mackenzie Miller Homes notes that the Vision or Strategic
Objectives set out in the PO document do not place much emphasis on meeting the
District’s housing needs, nor the District’s role in contributing towards addressing the
housing shortfall challenges within the Coventry & Warwickshire Housing Market Area
[C&WHMA], in which both Stratford-on-Avon District Council [SOADC] and Warwickshire
District Council [WDC] are part of, or Greater Birmingham and Black Country Housing
Market Area [GBBCHMA], in which only SOADC is part of.
2.3 It is noted that later in the PO document ‘Draft Policy Direction 4 – Accommodating
Growth Needs Arising from Outside of South Warwickshire’ considers the unmet housing
need from the neighbouring areas and ‘Draft Policy Direction 1 – Meeting South
Warwickshire’s Sustainable Development’ sets out the direction of local housing need
[LHN] for South Warwickshire. However, Mackenzie Miller Homes considers that there
should be more emphasis placed on the unmet need within the Vision and Strategic
Objectives to ensure that the policies tie in with the Vision and Strategic Objectives for
South Warwickshire.
2.4 The NPPF is clear that “to support the Government’s objective of significantly boosting the
supply of homes, it is important that a sufficient amount and variety of land can come
forward where it is needed, that the needs of groups with specific housing requirements
are addressed” (Para 60).
2.5 Moreover, it states 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 needs20; 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 36a).
2.6 The Government revised the NPPF in December 2024, which the emerging SWLP to 2050
must have regard to. In this context, the revised 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].
2.7 The SWC’s have not identified the unmet need for neighbouring areas as part of their
Strategic Objectives and therefore due to revisions to the NPPF and given the shortfalls
emerging throughout the C&WHMA and GBBCHMA, discussed later in this document,
Mackenzie Miller Homes strongly considers that to have a positively prepared Vision for the
District over the plan period, the Councils should include reference to meeting the housing
needs of its residents, alongside contributing in meeting the unmet housing needs of the
C&WHMA and GBBCHMA.