Other

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.

Other

ID sylw: 107893

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Terra welcomes that the PO acknowledges the SWA’s housing needs under the revised
Standard Method [SM] – see Table 4, whilst the PO refers to the housing needs established
in the ‘Coventry & Warwickshire Housing & Economic Development Needs Assessment
(HEDNA) (November 2022)’ (“the HEDNA”),
2.7 As the SWAs will be aware, the Government recently revised NPPF and SM for the
calculation of housing needs in December 2024. The proposed new SM significantly
increases the housing needs for the SWAs when compared to the HEDNA – as identified in
the PO, 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].
2.8 Notably, paragraphs 234 to 236 of the 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.
2.9 When taken together, and given the SWA’s working timetable for the SWLP, it is clear that
the SWAs will need to plan for the revised SM figure through the SWLP.
2.10 This is because the NPPF is clear that the overall aim of Local Plans should be to meet an
area’s identified housing need in full (Para 61) generated by the revised SM (Para 62), as the
SWLP will not have reached Regulation 19 by the 12th of March 2025. To this end, Terra
considers that the SWAs should seek to address the c.2,188 dwellings per annum [dpa]
LHN generated by the revised SM – or c.54,700 dwellings over the 2025 to 2050 plan
period within the SWLP for the period to 2050.
2.11 However, Terra would also highlight to the SWAs that it is expected that Local Plans should
be sufficiently flexible to adapt to rapid change. In practice, this means ensuring a housing
trajectory has sufficient land supply across the plan period so that it can adjust and
accommodate any unforeseen circumstances, such as a degree of flexibility in delivery rates
and densities. This means that to achieve a housing requirement a Local Plan must release
sufficient land or allow ‘headroom’ so that there is an appropriate buffer within the overall
planned supply.
2.12 As such, in due course, it will be necessary for the SWAs 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.
2.13 This ‘buffer’ should also be in excess of any commitments to addressing unmet housing
needs from neighbouring authorities – discussed further below in Terra ’ 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 SWAs, this would result in the unmet housing needs not being delivered. Therefore, Terra would recommend that a minimum of c.20%
headroom should be incorporated into the SWLP proposed housing supply.

Strategic Growth Locations
Given the scale of the SWA’s emerging housing needs under the new SM and the need to
make a contribution towards the unmet housing needs of the GBBCHMA, Terra strongly
supports the proposed ‘Sustainable Travel and Economy’ Spatial Growth Strategy. This is
because it will best promote sustainable patterns of development across the area and align
with the sustainability aspirations that are set out in the NPPF and SWLP Vision and
Objectives.
2.15 Ultimately, whilst greater levels of development may need to be focussed around the Main
Urban Areas, due to the level of infrastructure and services already present, it will also be
necessary to direct growth to other settlements to ensure that the benefits of housing
growth can be delivered in other parts of South Warwickshire to meet the need for new
housing.
2.16 Terra consider that there are several benefits to a mixed approach, to the distribution of
development:
1 It would support the well-being of those settlements that have the capacity to
accommodate growth;
2 By concentrating development around existing and proposed new employment
development and infrastructure, it would also ensure that it benefits from a sustainable
location with good access, such as at SG14 Gaydon/ Lighthorne Heath. Draft Policy
Direction 14 identifies this location as a Major Investment Site which follows the
findings of the South Warwickshire Employment Land Study (2024). The delivery of
additional jobs in this location will further enhance the important role of Gaydon as a
focus for economic growth within this part of South Warwickshire. This will create a
parallel demand for new homes and which Terra consider should be located in close
proximity, in order to ensure that sustainable patterns of growth are created and to
avoid unnecessary inward commuting from other part of South Warwickshire.
3 It can ensure that a sufficient supply of homes, within close proximity to existing and
future employment opportunities, such as those at Gaydon, contributes to an efficiently
functioning economy. This can also aid in minimising housing market pressures and
unsustainable levels of commuting (and therefore congestion and carbon emissions);
and
4 It would enable growth to meet the needs of neighbouring authorities to be located in
an area in close proximity to where these needs arise. Similar to the above, this also has
the added benefit of minimising housing market pressures and unsustainable levels of
commuting (and therefore congestion and carbon emissions).
2.17 Indeed, the NPPF is clear that planning policies should identify opportunities for
communities to grow and thrive, especially where this will support local services (Para 83).
Directing growth to existing settlements supports local services and also ensures
development is located sustainably in line with the NPPF (Para 11a). Existing settlements
often have access to education, healthcare, retail, jobs, and public transport, and should
therefore be considered as ideal locations for growth. Further growth can also broaden the
scope for these settlements to seek improvements to services and infrastructure, helping to address imbalances between the rural and urban areas in terms of provision and access to
facilities.
2.18 To this end, the NPPF is clear that planning policies and decisions should be responsive to
local circumstances and support housing developments that reflect local needs (Para 82).
Terra considers that the development on the edge of SG14- East of Gaydon and particularly
the Terra Site at Spring Farm) lends itself well to achieving these objectives, particularly
given the fact that the site is well-located in order for residents to access a range of key local
amenities and facilities. As such, Terra strongly considers that the SWLP should direct
growth to SG14- East of Gaydon in the SWLP.

Yes

ID sylw: 107896

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

As set out in Section 1.0 of these representations, Terra is promoting land at Stratford
Road, SGO14- East of Gaydon, for residential development.
2.20 Terra strongly supports the identification of the SGO14- East of Gaydon Group (SG24) as a
Strategic Growth Location within the PO. Whilst the location if positioned towards the
south of the SDC administrative area, it benefits from good accessibility to the local and
subregional transport network and remains accessible to local services and the main
conurbation of Stratford upon Avon and nearby Wellesborne as well as Warick/
Leamington Spa.
2.21 The locality is also a main location for existing and proposed employment growth and
which was recognised previously through the Gaydon/ Lighthorne Heath SPD which
advises that;
“The Gaydon site is a key economic asset within the District, County and West
Midlands more generally, employing several thousand people, together with
indirect employment in relation to logistics and suppliers. The site is located
adjacent to an established highway network, including the M40 which is an
important transport gateway into the wider West Midlands. It provides a
clear opportunity for growth and this is reflected throughout the document.”
2.22 Importantly, the development at Lighthorne Heath, which formed a main strategic
allocation through the Core Strategy was recognised by the Core Strategy Inspectors Report
dated 20/6/16 which concluded that;
“216. It has been claimed that it is inappropriate to focus a new settlement
around a single source of employment but, acknowledging that AML and JLR
are in the same industry, these are 2 of the country’s leading car
manufacturers. Both AML and particularly JLR appear to have significant
growth ambitions for this location, which gives rise to a need to provide an
appropriate range of housing options for their growing workforce. Whilst it
is recognised that there can be no guarantee that prospective residents will
work locally, particularly given the good access to the strategic road
network, paragraph 50 of the Framework emphasises that LPAs should
deliver a wide choice of high quality homes. Proposal GLH would match that
ambition by providing additional choice for current and future employees
who will have the potential to choose to rent or buy homes located in close
proximity to their workplace. There is the potential to reduce the high level of
in-commuting that is evident in the area at present.
217. The change to Strategic Objective 12 arose for reasons that were explored
in the IC and are unrelated to Proposal GLH. I reject the claim that it
represents a clear acknowledgement that the settlement will be car
dependent. There are significant opportunities to encourage walking and
cycling in order to access work and proposed local facilities, as well as scope
to use public bus services.”
2.23 The delivery of new development at Lighthorne Heath has of course now come forward and
has secured the delivery of new community and social infrastructure and further
development at SG140- East of Gaydon will be able to complement and add to the success
of the new settlement as a sustainable location for growth.
2.24 The delivery of further development at Lighthorne Heath would also support the role of the
settlement in the Districts hierarchy and ensure that the settlement provides opportunities
for local employment associated with the adjacent Jaguar and Aston Martin plants.
2.25 Importantly draft Policy Direction 12 proposes that the existing 100ha JLA allocation at
Gaydon (Proposal GLH in the SDC Core Strategy) should be released to the wider market
for strategic manufacturing (Use Class B2 use) uses and small-scale logistics (Use Class B8)
units.
2.26 Policy Direction 14 identifies the site as MIS1 as a Major Investment Site, which follows the
findings of the South Warwickshire Employment Land Study (2024) and sets out that;
“MIS.1 - Gaydon – JLR/AML – it is proposed to release the existing 100ha.
JLR restricted allocation to allow general strategic manufacturing and
small-scale logistics uses (under 9,300 sqm), with the emphasis on strategic
B2 manufacturing. Large-scale logistics (B8 class) uses will be resisted on
this site. We will engage with JLR regarding alternative sites that may be
suitable for their future development needs so that their requirements are
met. The existing Aston Martin Lagonda (AML) 4.5ha. allocation in the
adopted SDC Core Strategy may however be retained within the SWLP,
subject to further discussion with AML on their future plans for the site.”
2.27 Terra fully support the delivery of additional jobs in this location and which will further
enhance the important role of Gaydon as a focus for economic growth within this part of
South Warwickshire.
2.28 In addition, Terra support the commitment of the SWA’s to work with JLR to identify
potential alternative sites to meet their future development needs, which may result in
further growth at Gaydon in addition to that currently proposed in the PO.
2.29 The delivery of the MIS1 and additional employment growth will however generate a
parallel demand for new homes and associated community and social facilities. Terra
consider these should be located in close proximity, in order to ensure that sustainable
patterns of growth are created and to avoid unnecessary inward commuting from other part
of South Warwickshire.
2.30 Paragraph 77 of NPPF is clear that the supply of new homes should be well planned and
located where they can be supported by the necessary infrastructure and facilities
(including a genuine choice of transport modes). It sets out that;
In doing so, they should:
“a) consider the opportunities presented by existing or planned investment in
infrastructure, the area’s economic potential and the scope for net environmental gains;
b) ensure that their size and location will support a sustainable community, with sufficient
access to services and employment opportunities within the development itself (without
expecting an unrealistic level of self-containment)…”
Terr is therefore, seeking to promote the SG14 as an allocation for residential-led
development through the PO and emerging Local Plan Review. A Vision Document for the
site has been prepared in order to demonstrate the manner in which the site would be
brought forward in order to achieve sustainable growth and to deliver the residential led
needs identified within the PO and to align with the proposals for economic growth. This is
appended to these representations (Appendix 1).
2.31 The land forming part of SG14 - East of Gaydon comprises c.115ha of land currently part of
land known as Spring Farm. It is located directly east of the M40 Junction 12, which has
recently been subject to highways upgrades that have facilitated increased junction capacity
and that has also enabled the delivery of the Lighthorne Heath new settlement.
2.32 The settlement benefits from a range of existing and new key local amenities and facilities,
including the SG14- East of Gaydon village centre convenience store, a Post Office, Dental
Surgery and Primary School.
2.33 The Site has no physical constraints that would prevent development. There is limited
vegetation on the sites, with the exception of some trees and boundary vegetation. Design
proposals would positively seek to retain and enhance any trees and hedgerows where
possible within the Site as part of the placemaking strategy, subject to detailed studies and
further technical work.
2.34 In this regard, the Vision Document (Appendix 1), submitted in support of these
representations, demonstrates how the Site could deliver a medium-sized sustainable
development of up to 1550 new market and affordable homes. It would also deliver new
community and social infrastructure to complement existing facilities at Lighthorne Heath
including a significant new Linear Park and landscape buffer and open space to secure
permanent separation of development from Bishops Itchington to the north.
2.35 The Vision Document demonstrates how the Site could deliver a residential development
that addresses the SWLP’s Vision and Strategic Policy Objectives in relation to delivering
sustainable growth and combating climate change in South Warwickshire.
2.36 The design’s scale and form can cater to a range of house types and living styles, including
self-and custom-build plots, retirement housing and community-led housing projects. All
homes would be integrated within an attractive and well-connected network of low-traffic
streets and green corridors.
2.37 The design embraces high-quality placemaking principles and shows how the SWLP’s
Vision and Strategic Policy Objectives can achieved on this site, with the result being a
sensitive, valuable and logical new edge to SG14- East of Gaydon. The key components of
the Concept Plan are:
1 Up to 1550 new homes, delivered across three phases, including the flexibility for a
range of different housing models to be integrated.
2 A 3FE primary school and nursery;
3 A 1ha local centre (includes 0.6ha extra care, plus health, community, retail) and a
Smaller 0.3ha retail local centre along Gaydon Road in order to collectively deliver
facilities to meet the daily needs of residents and new employees.
4 Significant level of new open space to include a new 28ha Linear Park that would
provide recreational facilities to support the new development but also to complement
the existing communities at Lighthorne Heath;
5 A significant landscape buffer to Bishops Itchington to the north;
6 A mosaic of sustainable drainage solutions, across the site, will capture surface water
runoff close to the source and enhance the visual amenity of the public realm.
7 A legible and accessible strategy, providing direct pedestrian and cycle links to local
facilities and services, encouraging active modes of travel for local trips.
8 Retention and integration of existing landscape to protect biodiversity and secure a
unique identity that responds to the natural environment.
9 Provision of generous space for enhancements to biodiversity and ecology through the
retention of existing trees and hedgerows (where possible) and the planting of new
vegetation, that will deliver overall environmental net gain.
2.38 Overall the site would deliver c48ha built development consisting of residential, local
centres, primary school. This equates to 42% of site area, therefore 58% of site retained as
open space/green setting

Yes

ID sylw: 107897

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Suitable, Available and Achievable
2.39 The Site was assessed in the SWA’s ‘Housing and Economic Land Availability Assessment
(2024)’ [HELAA] under Site Reference: 759. The Site was assessed through the Part A and
Part B HELAA assessments and was recommended to remain in consideration for the
SWLP – a conclusion that Terra welcomes and supports. The site scored 59.13 through the
HELAA Part B assessment, albeit the site was assessed as suitable for employment use.
2.40 The SWAs will be aware of the importance of demonstrating the deliverability of all sites
that are proposed for allocation when SWLP is examined for soundness. If allocated, it is
considered the Site could be developed in the short-medium term for residential use. In this
regard, Annex 2 of the NPPF states that to be considered deliverable, “sites for housing
should be available now, offer a suitable location for development now, and be achievable
with a realistic prospect that housing will be delivered on the site within five years.”
2.41 In this context, Terra wishes to reaffirm the Site’s status as being ‘suitable, available and
achievable’ and that Terra ’ s Vision for the Site is predicated upon evidence which ensures
that there are no environmental or technical constraints to the development of the Site.
Importantly, Terra have the capability and expertise to deliver this Vision for the Site and is
committed to working constructively with the SWAs and local stakeholders through the
plan-making process.
Delivery Timescales
2.42 As noted above, it is envisaged that the Site could be developed in the short/ medium term
with development taking place within the early years following plan adoption, with the
remaining development phases over the period to 2050 across three overall phases:
• Phase 1 could provide approximately 550 homes and a community facility, with primary
vehicle access from Gaydon Road and new pedestrian and cycle access points. This
phase would also include a linear park, ancillary public open spaces, supporting
infrastructure, and SuDS, along with delivery of land for a 3FE primary school.
• Phase 2 could add an additional 500 homes, introducing a second vehicle access from
Gaydon Road. It would also feature expanded public open spaces, further supporting
infrastructure, SuDS.
• Phase 3 would deliver a further c500 dwellings, including a buffer to Bishops
Itchington, additional open space, supporting infrastructure and SUDS.
2.43 It is envisaged that subject to the Site being allocated in a future Regulation 19 SWLP, Terra
would seek to submit a planning application in advance of the Examination in Public to
assist the SWAs in demonstrating the deliverability of the allocation to Inspectors.
2.44 Assuming the SWLP is adopted in line with the SWA’s timetable (i.e. December 2027), and
the application is approved shortly thereafter, delivery on Phase 1 could begin within 3
years, meaning that the development could form part of the SWLP’s five-year housing land
supply.
2.45 In respect of the delivery trajectory, Terra envisages the Site could be delivered broadly in
line with the below trajectory and deliver well within the SWLP plan period: [table available in attachment]

Approach to achieving net zero
2.46 Terra ’s Vision for the Site ensures that the development could deliver on the SWLP’s Vision
and Strategic Policy Objectives in relation to delivering sustainable growth and combating
climate change. Further information on how Terra proposes to achieve this is set out in
detail in the supporting Vision Document (Appendix 1).
2.47 However, in short, the Site could deliver a suite of ecological and green infrastructure
improvements throughout the proposed development, ensuring a 10% Biodiversity Net
Gain [BNG] alongside blue-infrastructure enhancements and a Linear Park and landscape
buffer to Bishops Itchington in the north.
2.48 When coupled with a fabric-first approach to the build specification that will ensure that
new homes will reduce heat waste and incorporate low-carbon energy generation
technologies, and electric vehicle charging points, the Site is well placed to assist the SWAs
in achieving Net Zero.
Mitigation of issues identified through the SA
2.49 Based on the SA conclusions, SG14 broadly ranks toward the lower end of the twenty-four
SGLs in terms of best and worst-performing SGLs against the Sustainability Appraisal [SA]
objectives, set out in the ‘Interim Sustainability Appraisal of the South Warwickshire Local
Plan Regulation 18: Preferred Options Stage’.
2.50 However, it is considered that this fails to take into account the impact of mitigation
through the delivery of the scheme to include new community and social infrastructure as
identified within the Vision Document at Appendix 1. This is made clear in the SA which
advises that: “Mitigation has not been considered when ranking the SGLs, given the
options requiring less intervention are likely to be more sustainable choices.” However,
2.51 Terra have set out below how the Site could mitigate against any of the impacts identified
within the SA: [table visible in attatchment]

It should be noted that further technical work can be provided to the SWAs to demonstrate
that the Site could mitigate any negative impacts arising from development and which will
build upon the position set out in the Vision Document at Appendix 1.

Yes

ID sylw: 107898

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Yes, Terra considers that it is clear that the step-change in delivery required to meet the
SWA’s SM LHN figures, and any unmet housing needs from the GBBCHMA, will require a
suite of new sites to be allocated throughout the SWLP area – including the potential for
Strategic Growth Areas and New Settlements. Indeed, the NPPF is clear that the supply of
large numbers of new homes can often be best achieved through planning for larger-scale
developments (Para 74), such as New Settlements.
2.54 Importantly, however, it is also clear that plans should be prepared positively, in a way that
is aspirational but deliverable (Para 16b) and should set out an appropriate strategy, taking
account of reasonable alternatives, and be based on proportionate evidence (Para 35b). As
such, the SWAs also need to robustly test reasonable alternatives for the spatial distribution
of South Warwickshire’s housing needs through the SA process at an early stage. In
addition to the above, it is also important to note that the NPPF shifts the need to consider
viability to the plan-making stage, requiring authorities to identify a sufficient supply and
mix of sites, taking into account their availability, suitability and likely economic viability
(Para 67).
2.55 The Planning Practice Guidance [PPG] provides further clarity for new settlements, stating
that LPAs should demonstrate that there is a reasonable prospect that large-scale
developments can come forward. In particular, this should include a realistic assessment of
the prospect of sites being developed and should engage with infrastructure providers to
ensure that the infrastructure requirements are not beyond what could reasonably be
considered to be achievable within the planned timescales.1
2.56 In this context, Terra would not object to the option of exploring meeting some of the
SWA’s needs through a New Settlement but wishes to highlight to the SWAs that sufficient
evidence will need to be prepared in support of any future allocation. Terra would note that
such forms of development should not be viewed as the panacea for meeting all of the
SWLP’s needs.
2.57 New Settlements by their very nature require significant upfront commitment to the
delivery of new community, physical and social infrastructure and are often challenged in
terms of viability through the initial phases of development, requiring significant public
sector investment. These types of development can take some years to come onstream and begin delivering, and the SWAs will need a spatial strategy that allocates a supporting
package of ‘suitable, available, and achievable’ sites at different scales throughout the SWLP
area in sustainable locations to ensure that supply can come forward in the earlier parts of
the plan period to meet housing needs in the interim – such as SG14- East of Gaydon.

Other

ID sylw: 107899

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Whilst Terra welcomes the SWA’s acknowledgement that the SWLP may need to play a role
in addressing the unmet housing need of neighbouring authorities within the Coventry &
Warwickshire Housing Market Area [C&WHMA]2 and Greater Birmingham and Black
Country Housing Market Area [GBBCHMA]3, Terra has some concerns regarding the
SWLP’s proposed approach.
2.59 The SWLP proposes – albeit not explicitly – to only assist with addressing the unmet
housing needs of the C&WHMA and GBBCHMA only when these unmet needs are defined,
and through the release of ‘reserve sites’. In this respect, the PO does not identify any
‘reserve sites’.
2.60 The NPPF emphasises that local planning authorities [LPAs] must cooperate to identify and
meet housing needs within their housing market areas [HMA] (Para 11b), and that plans
should be supported by relevant and up-to-date evidence (Para 32). It also reiterates that
LPAs’ continue to be under a Duty to Cooperate [DtC] (Para 24). 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.” (Para 28)
2.61 In this context, given the acuteness of the situation in these HMAs – outlined in detail
below – it will be necessary for the SWLP to make provision for any unmet housing needs
arising from these HMAs at the point 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.
2.62 Given that the SWLP area sits within the two HMAs, both with serious historic housing
land supply challenges, Terra considers that based on the current evidence, that the SWLP
will need work with the adjoining LPA’s through this plan making stage to accommodate
some of these needs.
2.63 By way of example, whilst there is some degree of uncertainty regarding whether there will
be any unmet housing needs arising from the C&WHMA, it is plain to see 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,4 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].5 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.
2.64 At present, only Shropshire (1,500), South Staffordshire (640), Cannock Chase (500),
Stafford (2,000) and Telford & Wrekin (1,6806) are proposing to contribute towards
addressing these unmet housing needs. Collectively, 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. 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 SWAs effectively delivering on their DtC.
2.65 Ultimately, 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 SWAs and wider
GBBCHMA authorities will need to make appropriate contributions towards addressing
these needs now. As such, 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.
2.66 In terms of how much of these needs the SWAs 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).
2.67 However, as the SWAs 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.
2.68 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)
2.69 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.
2.70 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.
2.71 The above serves to highlight that there is evidence to suggest that the SWAs should be
seeking to make an appropriate contribution through the SWLP now, rather than deferring
it, in accordance with paragraph 35c of the NPPF. Terra considers that given the relatively
modest contribution required of SOADC when compared to the SWA’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.
2.72 Terra considers that it is likely that there are sites throughout the SWLP area that could
sustainably contribute to addressing the SWA’s own housing needs and a proportion of the
GBBCHMA’s unmet housing needs. Indeed, it is evident that there are opportunities to
allocate ‘suitable, available and achievable’ land and sites in sustainable locations across
South Warwickshire. Indeed, Terra ’ site at SG14- East of Gaydon is just one of these
opportunities.

Yes

ID sylw: 107901

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

In general, Terra agrees with the SWA’s proposed approach of requiring developments to
make contributions towards the delivery of infrastructure. It is entirely appropriate for
development to mitigate their impacts and where possible and necessary make contributions towards associated infrastructure. However, as the SWAs will be aware, these
contributions must:
a necessary to make the development acceptable in planning terms;
b directly related to the development; and
c fairly and reasonably related in scale and kind to the development (Para 58,
NPPF).
2.74 As such, as the SWAs progress the SWLP, it will be critical that an Infrastructure Delivery
Plan [IDP] is prepared, which identifies the infrastructure necessary to mitigate proposed
development allocations – this will be particularly critical for any SGLs or New Settlements.
2.75 However, the NPPF is clear that planning policies should be “clearly written and
unambiguous, so it is evident how a decision maker should react to development
proposals” (Para 16d). In addition, Paragraph 34 clearly states that:
“Plans should set out the contributions expected from development. This should include
setting out the levels and types of affordable housing provision required, along with other
infrastructure (such as that needed for education, health, transport, flood and water
management, green and digital infrastructure). Such policies should not undermine the
deliverability of the plan.”
2.76 Therefore, it will be critical that the SWLP is clear through site-specific allocations what
infrastructure improvements are required for each development allocation. The need for
the delivery of supporting new community and social infrastructure has formed the basis
for Terra ’s vision of the land at SG14- East of Gaydon and is illustrated within the Vision
Document at Appendix 1 to include a new 3FE primary school, new access routes,
pedestrian and cycle infrastructure, a Linear Park and significant landscape buffer to
Bishops Itchington, along with SUDS feature and drainage infrastructure.

Other

ID sylw: 107903

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

As the SWAs will be aware, the NPPF is clear that:
“Once established, Green Belt boundaries should only be altered where exceptional
circumstances are fully evidenced and justified through the preparation or updating of
plans.” (Para 145)
2.78 It goes on to state that:
“Exceptional circumstances in this context include, but are not limited to, instances where
an authority cannot meet its identified need for homes, commercial or other development
through other means. If that is the case, authorities should review Green Belt boundaries
in accordance with the policies in this Framework and propose alterations to meet these
needs in full, unless the review provides clear evidence that doing so would fundamentally
undermine the purposes (taken together) of the remaining Green Belt, when considered
across the area of the plan” (Para 146)
2.79 The NPPF further sets out a sequential approach required to be demonstrated prior to
concluding that ‘exceptional circumstances’ exist. This includes utilising brownfield land, optimising densities and engaging with neighbouring authorities to assist in meeting needs
(Paragraph 147). Therefore, when considering the sequential approach required to
demonstrate whether ‘exceptional circumstances’, it is clear that there is insufficient
brownfield land across South Warwickshire, and that optimising densities is also unlikely to
meet the SWA’s needs in full.
2.80 It is also unlikely that other authorities within the C&WHMA are able to assist in meeting
the SWA’s needs, as they are equally as constrained by Green Belt or tight administrative
boundaries. When taken together and given the scale of the SWA’s housing needs under the
new SM, it is clear that ‘exceptional circumstances’ can be demonstrated and Green Belt
release should be explored within the SWLP.
2.81 It is the case however, that land that is capable of delivering sustainable development
should be the first choice in the selection of locations for new development. To this end,
Terra strongly support the SWLP identifying potential SGLs including land within and
outside of the Green Belt – particular land around SG14- East of Gaydon. Importantly, in
exercising policy choice regarding the section of appropriate sites and taking into account
the designation of land, SGO14- East of Gaydon falls entirely outside if the Green Belt, and
is not subject to any significant land use designation that would preclude development from
coming forward.
2.82 In addition, the settlement is well located in order for residents to access a range of key
local amenities and facilities, both Gaydon and Lighthorne Heath, and would also benefit
from the economic growth planned at JLR, including significant safeguarded land for future
jobs growth.

Yes

ID sylw: 107904

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Yes, paragraph 63 of the NPPF states that the size, type and tenure of housing needed for
different groups (including those who require affordable housing) should be reflected in
planning policies. Paragraph 32 states that all policies should be “underpinned by relevant
and up-to-date evidence”, which “should be adequate, proportionate and focussed tightly
on supporting and justifying the policies concerned.” Terra therefore agrees that the SWAs
should have regard to the latest evidence in drafting policies relating to housing tenure and
type in due course, in accordance with the NPPF.
2.84 In addition, Paragraph 16(d) of the NPPF states that policies should be “clearly written and
unambiguous, so it is evident how a decision maker should react to development
proposals.” In addition, Paragraph 34 clearly states that:
“Plans should set out the contributions expected from development. This should include
setting out the levels and types of affordable housing provision required, along with other
infrastructure (such as that needed for education, health, transport, flood and water
management, green and digital infrastructure). Such policies should not undermine the
deliverability of the plan.”
2.85 The NPPF is also clear that planning policies should have regard to the economic viability of
sites (Para 72) and should not undermine the deliverability of the Local Plan (Para 35). Crucially, both the NPPF and PPG are clear that contributions should be tested through the
viability process, so as to ensure that they do not undermine the deliverability of the plan.
2.86 In this regard, it is acknowledged that the SWAs have not quantified a proposed affordable
housing requirement yet. The PPG7 is also clear that the SWLP should seek to meet as much
of its identified affordable housing needs as possible, albeit, the SWLP is not required to
meet its affordable needs in full.8 In this context, it will be critical for the SWAs to test
different requirements through the Viability Assessment to ensure that it would not
undermine the deliverability of the SWLP on the whole (i.e. Para 34) – this will particularly
be the case for allocations within the Green Belt within the context of the NPPF’s ‘Golden
Rules’ (Paras 67, 68 and 156a).
2.87 Notwithstanding the above, Terra would also support the inclusion of a viability caveat
within the future affordable housing policy to enable flexibility where it is required and can
be justified. The NPPF is clear that planning policies should be flexible enough to adapt to
unforeseen circumstances and changing economic conditions (Paragraph 82d). As such,
Terra considers that such a caveat would allow developers to react flexibly to changing
economic circumstances, and suggests the below wording:
“Lower proportions of affordable housing will only be accepted where a viability
assessment, prepared in accordance with national planning policy and guidance, clearly
demonstrates that the full policy requirement cannot be achieved.”

Yes

ID sylw: 107905

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Draft Policy Direction-11 sets out a policy approach with regard to the delivery of GTAA
accommodation and that the Local Plan will require the provision of pitches and plots on
large scale development sites (of over 500 homes) to meet the identified need as set out in
the latest GTAA accommodation assessment (or any subsequent update).
2.89 Draft Policy Direction 11 in relation to gyspies and travellers? We can accommodate their
requirement for all sites over 500 dwellings to include pitches. Apparently, the Officers
have been keen to emphasis this as a necessity in recent public events. It therefore does us
no harm to be compliant. The intention is that GTAA will be able to be better integrated
with the emerging localities and communities.
2.90 In doing so, this will enable the provision of Gypsy and Traveller accommodation at
sustainable locations with good access to a range of facilities.
2.91 Terra supports the approach set out in the PO and can confirm that it envisages that the
land forming SG14 will be able to accommodate a proportionate level of GTAA.