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ID sylw: 108366

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

6.1 Mackenzie Miller Homes welcomes the SWC’s acknowledgement that they may need to play
a role in addressing the unmet housing need of neighbouring authorities within C&WHMA
and GBBCHMA however, Mackenzie Miller Homes has some concerns regarding the
SWLP’s proposed approach.
6.2 The SWLP implicitly proposes to assist in addressing the unmet housing needs of the
C&WHMA and GBBCHMA, only when these needs are clearly defined, and through the
release of ‘reserve sites’. However, at this stage, the PO document neither identifies any
‘reserve sites’ nor does it address this issue in its commentary on the proposed spatial
strategy.
6.3 Notably, Paragraph 11b of the NPPF emphasises that LPAs must cooperate to identify and
meet housing needs within their housing market areas [HMA], and that plans should be
supported by relevant and up-to-date evidence as set out in Paragraph 32. It also reiterates,
in Paragraph 24, that LPAs’ continue to be under a DtC. In Paragraph 28 of the NPPF, it is
also clear that:
“Plans come forward at different times, and there may be a degree of uncertainty about
the future direction of relevant development plans or the plans of infrastructure
providers. In such circumstances strategic policy-making authorities and Inspectors will
need to come to an informed decision on the basis of available information, rather than
waiting for a full set of evidence from other authorities.”
6.4 Given the severity of the situation in these HMAs, as detailed below, it is essential for the
SWLP to address any unmet housing needs from these HMAs at the time of adoption,
rather than deferring this matter to a time when the unmet needs have been ‘evidenced’ and
through the release of ‘reserve sites’. Indeed, this is particularly pertinent, given the
Inspector’s recent findings in respect of the Solihull Local Plan Review where problems of
Birmingham’s unmet need were not adequately addressed within the plan, resulting in a
terminal failure of the soundness of the plan.
6.5 Whilst Mackenzie Miller Homes notes that there is no single, or definitive, approach to
determining the proportion of unmet needs that any single area should accommodate. In
any event, given that the SWLP area sits within the two HMAs, both with serious historic
housing land supply challenges, Mackenzie Miller Homes considers that there is an
extremely high level of certainty based on the current evidence that the SWLP will need to
accommodate some of these needs.
6.6 By way of example, there is some degree of uncertainty regarding whether there will be any
unmet housing needs arising from the C&WHMA, it is clear that the SWLP will need to
assist in meeting the unmet housing needs of the GBBCHMA up to 2042 at the very least.
Indeed, despite the revisions to the NPPF and SM alleviating pressures in the GBBCHMA in part,1 a significant housing shortfall across the GBBCHMA remains, with an estimated
cumulative shortfall of c.42,900 homes across the WMCA up to 2042 under the SM, arising
from the Black Country Authorities [BCAs].2 To address these needs, the BCAs are actively
seeking to export these needs into the GBBCHMA, of which the SOADC falls within, to be
addressed through the forthcoming Local Plan.
6.7 At present only the authorities set out in Table 1 below are proposing to contribute towards
these unmet housing needs:

6.8 Together, this would equate to only 6,320 dwellings between 2018 and 2042, but, notably,
several of these plans have stalled or are at risk of being found unsound in due course.
6.9 Notwithstanding the uncertainty regarding these ‘contributions’, a significant unmet
housing need would still remain within the GBBCHMA. As such, at present, there is an
unaccounted shortfall up to 2042, which is substantial given the urban context of the BCAs,
meaning that a significant proportion of the unmet need will be deferred rather than dealt
with, contrary to Paragraph 35c of the current NPPF. This highlights the importance of
SWCs effectively delivering on their DtC.
6.10 There is a significant, and persistent level of unmet housing need across the GBBCHMA
and even with some Green Belt releases in the BCAs it is unlikely to markedly reduce the
GBBCHMA’s significant shortfall of housing. To this end, the SWCs and wider GBBCHMA
authorities will need to make appropriate contributions towards addressing these needs
now. Therefore, whilst there remains some uncertainty regarding the exact amount of
unmet housing needs, under the revised NPPF, the SWLP will need to make provisions
based on the current level of information, rather than deferring until these unmet needs are
defined.
6.11 In terms of how much of these needs the SWCs should be addressing through the SWLP, it
is noted that there is not a single, or definitive, approach to determining the proportion of
unmet needs that any single Council should accommodate. That being said, the NPPF is
clear that Local Plans should be based on ‘proportionate evidence’ (Para 35c).
6.12 However, as the SWCs will be aware, Lichfields has historically provided an evidence-led
approach for how to distribute previous unmet housing needs sustainably. In particular,
Lichfields’ Black Country’s Next Top Model analysis considers the functional housing
market relationship between the various local authority areas in the GBBCHMA and the
origin-authorities of the unmet housing needs.
6.13 It should be noted that of the current contributions towards the BCA's unmet needs,
Wolverhampton has highlighted that the BCAs are attributing proportions based on
migration trends:
“is important to develop an evidence-led approach to dividing up such contributions
between authorities across the wider Greater Birmingham and Black Country Housing
Market Area (HMA) which have a housing shortfall. The proposed approach, which has
been agreed by the Black Country authorities, is to divide up contributions based on the
proportion of historic net migration flows between the contributing authority and
shortfall authorities.” (Para 4.6, Wolverhampton Local Plan - Regulation 19 Consultation
Cabinet Report 13th November 2024) (Emphasis Added)
6.14 Importantly, Lichfields’ approach (i.e. Functional Relationship) aligns broadly with the
BCA’s approach to apportioning proposed unmet need contributions to the BCAs as a
whole. Such an approach was also adopted by the approach taken in distributing Coventry’s
unmet needs across the C&WHMA previously. Again, the Inspector for the Stratford-on-
Avon Core Strategy (2017) endorsed this approach. More recently, in considering how the
unmet housing needs of Leicester could be addressed throughout the Leicester and
Leicestershire Housing Market Area [LLHMA] a similar functional relationship approach
was utilised and has been accepted by Inspectors at the Charnwood EiP.
6.15 Notably, Lichfields analysis takes account of the degree of migration and commuting
linkages within the GBBCHMA to the BCAs, opportunities to capitalise on sustainable
transport links and improve affordability, and the degree of environmental and physical
constraints which might impede on an authority’s ability to accommodate unmet housing
need. The analysis ultimately illustrates the functional linkages between the authorities
within the GBBCHMA, and the origins of the unmet housing need (i.e. the BCAs), and
shows how the BCA’s unmet housing needs could be sustainably distributed. For SOADC,
Lichfields’ functional housing market relationship analysis indicates that the SOADC
should be seeking to make provision for c.1% of the total unmet needs of the BCAs – or
around c.500 dwellings based on the current level of unmet need.
6.16 The above serves to highlight that there is evidence to suggest that the SWCs should be
seeking to make an appropriate contribution through the SWLP now, rather than deferring
it, in accordance with paragraph 35c of the NPPF. Mackenzie Miller Homes considers that
given the relatively modest contribution required of SOADC when compared to the SWC’s
own housing requirement up to 2050, it would be entirely reasonable and sustainable for
the SWLP to make provision for this within the SWLP. Mackenzie Miller Homes also
considers that it is likely that there are sites throughout the SWLP area that could
sustainably contribute to addressing the SWC’s own housing needs and a proportion of the
GBBCHMA’s unmet housing needs.
6.17 Indeed, it is evident that there are opportunities to allocate ‘suitable, available and
achievable’ land and sites in sustainable locations across South Warwickshire of which,
Mackenzie Miller Homes’ Site in Shipston-on-Stour is considered as one of them.