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ID sylw: 108362

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

The SWCs will be aware, that the Government recently revised NPPF and Standard Method
[SM] for the calculation of housing needs. Whilst the PO document refers to the housing
needs established within the ‘Coventry & Warwickshire Housing & Economic Development
Needs Assessment (HEDNA) (November 2022)’ (“the HEDNA”), Mackenzie Miller Homes
welcomes that the PO recognises the SWC’s housing needs under the recently revised SM.
3.2 As identified in the PO, when compared to HEDNA, the new proposed SM would
significantly increase the housing needs for the SWCs, with the SWLP having to identify a
further c.12,725 dwellings to meet these needs when compared to the HEDNA’s objectively
assessed housing needs [OAHN].
3.3 It is important to note that paragraphs 234 to 236 of the revised NPPF are clear that Local
Plans that do not reach Regulation 19 by the 12th of March 2025 and are planning to meet at
least 80% of the local housing need [LHN] figure generated by the revised SM would be
required to take full account of the revised NPPF policies, in addition to the updated LHN
figures generated by the revised SM.
3.4 Considering the SWC’s timetable for the SWLP, it is evident that the SWCs must
incorporate the revised SM figure into the SWLP. The NPPF mandates that Local Plans
should fully meet the identified housing needs of an area (Para 61) as determined by the
revised SM (Para 62).
3.5 Since the SWLP will not reach Regulation 19 by 12th of March 2025, Mackenzie Miller
Homes believes that the SWCs should aim to accommodate c.2,188 dwellings per annum
(dpa) LHN as per the revised SM, equating to around 54,700 dwellings for the 2025 to
2050 plan period.
3.6 Nevertheless, Mackenzie Miller Homes would like to emphasise to the SWC’s that it is
expected that Local Plans should be sufficiently flexible to adapt to rapid change. In
practice, this involves ensuring that the housing trajectory includes enough land supply
throughout the plan period to adapt to unforeseen circumstances, such as flexibility in
delivery rates and densities. Essentially, to meet housing requirements, a Local Plan must
allocate enough land or provide sufficient 'headroom' to create an appropriate buffer within
the overall planned supply.
3.7 Therefore, in due course, it will be necessary for the SWCs to identify suitable land supply
in excess of the SWLP’s LHN-based housing requirement, to ensure that there is the
flexibility to respond to failures to deliver the required dwellings in the allotted time frames
and across the whole plan period.
3.8 Importantly, this ‘buffer’ should also be in addition of any commitments to addressing
unmet housing needs from neighbouring authorities as discussed further below in Mackenzie Miller Homes’ response to Draft Policy Direction 4. This is because if any single
component of supply does not come forward or falls behind the timescales implied by the
SWCs, which buffers are intended to address this would result in the unmet housing needs
not being delivered, rather than the SWLPs. Therefore, Mackenzie Miller Homes would
recommend that a minimum of c. 20% headroom should be incorporated into the SWLP
proposed housing supply.
3.9 Mackenzie Miller Homes strongly considers that the SWC’s must provide robust evidence to
justify the proposed windfall rate of 375 dwellings per annum. This evidence should include
historical data on windfall site delivery and an analysis of future trends to ensure the rate is
realistic and achievable.
3.10 Furthermore, Mackenzie Miller Homes urges the SWC’s to consider increasing specific
allocations now. This approach would provide greater certainty in meeting housing targets
and reduce reliance on windfall sites, which may not consistently deliver the anticipated
numbers. By allocating more specific sites, the SWC’s can ensure a more reliable and
deliverable housing supply, supporting the overall objectives of the Local Plan.