Other

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.

Other

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.

Yes

ID sylw: 108363

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

3.11 Part of the ‘Draft Policy Direction 1 – Meeting South Warwickshire’s Sustainable
Development’ focuses on Strategic Growth Locations’ [SGLs]. The PO document has
identified twenty-four areas as locations for potential strategic growth, however, it is
acknowledged that not all of those locations will be allocated.
3.12 The PO document has identified SG17 as comprising land to the east of Shipston on Stour.
Mackenzie Miller Homes is highly supportive of the SG17 (Shipston-on-Stour) which would
enable the delivery of development on non-Green Belt land and in a sustainable location
adjacent to the centre of the town.
3.13 It is noted that the Interim Sustainability Appraisal [SA] for Regulation 18 SWLP assesses
the SGLs against each of the 13 SA Objectives and that currently, all assessments are based
on a desktop review of available data provided by the SWCs and information publicly
available about receptors and sources. The SA specifically does not include potential
mitigation within the assessments for each of the sites and which Mackenzie Miller Homes
would suggest will need to be factored in as part of a stage 2 assessment as the Council’s
moves towards a Regulation 19 Local Plan.
3.14 Based on the SA conclusions, SG17 performs well compared to the other twenty-four SGLs
in terms of best and worst-performing sites.
3.15 Mackenzie Miller Homes highlights that SG17 is one of the best performing in SA Objective
10: Health. Shipston-on-Stour SGL is expected to result in positive impacts on access to
leisure and greenspaces.
3.16 In addition, SG17 is also one of the best-performing sites in SA Objective 11: Accessibility.
Shipston-on-Stour SGL is in close proximity to existing food stores, and bus stops and lies
within Priority Area 2. In this respect, SG17 will deliver development immediately adjacent
to the town centre and will enable the creation of a 20 minute neighbourhood concept
where all of the day to day needs of residents are available within a short walk or cycle. 3.17 Whilst Mackenzie Miller Homes notes that the Site does not perform particularly high in SA
Objective 2: Flood Risk it is considered that these matters are resolvable through
appropriate mitigation – indeed, as stated within the SA: “Mitigation has not been
considered when ranking the SGLs, given the options requiring less intervention are likely
to be more sustainable choices.” Indeed, the supporting Vision Document demonstrates
that no development would be located in areas susceptible to flood risk.
3.18 Mackenzie Miller Homes fully support the proposition that greater development should be
located adjacent to existing urban centres and consider that there are several benefits to
such an approach being adopted within the SWC’s strategy for accommodating growth as
this would; :
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 infrastructure, it
would also ensure that it benefits from a sustainable location with good access, such as
at SG17. Such an approach would allow the SWAs to capitalise on opportunities
presented by existing or planned infrastructure when considering options for largescale
new residential developments, in accordance with paragraph 77a of the NPPF;
3 It can ensure that a sufficient supply of homes, within close proximity to existing and
future employment opportunities, such as those at Shipston on Stour, 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 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).
3.19 Indeed, paragraph 83 of the NPPF is clear that planning policies should identify
opportunities for communities to grow and thrive, especially where this will support local
service. 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.

Potential at Land at Fell Mill and Leasow Farm,
Shipston-on-Stour
3.20 SG17 has been identified as one of the SGLs outside of the Green Belt within the South
Warwickshire Local Plan Green Belt Review Stage 1 Report (September 2024). It is noted
that, unlike many other SGLs within the District, the settlement of Shipston-on-Stour is not
surrounded by, nor within, the Green Belt, which creates an opportunity for the settlement
to accommodate higher levels of growth without requiring the release of Green Belt land.
3.21 Mackenzie Miller Homes considers that it is essential that the Council adopts a sequential
approach when considering land allocations for development where non-Green Belt sites should be prioritised for housing development before any consideration is given to the
release of Green Belt land.
3.22 The revised NPPF provides a sequential framework for Green Belt land release. Paragraph
148 states that “Where it is necessary to release Green Belt land for development, plans
should give priority to previously developed land, then consider grey belt land which in
not previously developed, and then other Green Belt Locations.”
3.23 Mackenzie Miller Homes believes that the Council should first identify and prioritise non-
Green Belt sites, including sites such as land at Fell Mill and Leasow Farm, Shipston-on-
Stour. It is considered that such an approach is fundamentally required by the NPPF, and
once this sequential approach has been satisfied, the Council can then release land from the
Green Belt.
3.24 The SWCs will also be aware of the importance of demonstrating the deliverability of all
sites that are proposed for allocation when the emerging Local Plan is examined for
soundness. The Vision for the Site will be predicated upon evidence which ensures that
there are no unresolvable environmental or technical constraints to the development of the
Site.
3.25 In addition to this, the SWC’s can be confident that the Site could be delivered in the
timescales envisaged and could begin delivering in the first five years of the plan period.
3.26 Mackenzie Miller Homes will directly deliver new housing and as such there would be no
need for the Site to be sold prior to seeking planning permission and commencing
housebuilding.
3.27 This further demonstrates the deliverability of the Site. If allocated, it is considered the Site
could be developed in the short-medium term. 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.” In this regard, Mackenzie Miller
Homes can confirm that the Site is ‘suitable, available and achievable’.
3.28 Furthermore, the town itself offers many services and facilities, which support the local
community. Conveniently accessible by public transport or on foot, these include – Tesco
and other convenience stores, post office, cafés, restaurants, pubs, takeaways, pharmacy, a
leisure centre and many other facilities. The settlement is also served by Shipston-on-Stour
Primary School and Shipston High School.
3.29 The Illustrative Masterplan (within the appended Vision Document in Appendix 1) shows
its capacity to support residential development that aligns with the settlement’s character
and addresses both local and wider rural housing needs.
3.30 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 1,150 new market and affordable homes. Mackenzie Miller Homes
vision for the site would focus on delivery of five key themes to include;
Place making- a landscape led approach
• Potential for delivery of a new bridge across the River Stour;
• Provision of a riverside park, public open space, and play areas for children will provide
opportunities for social interactions. Additionally, creating a central green focal point
within the new centre of Shipston-on-Stour will further enhance community cohesion
and provide a vibrant, accessible space for local people to gather and engage in various
activities.
Community and Social Facilities
• Provision of a local centre;
• Provision of a 2FE Primary School; and
• An 80-bed care facility.
Active Travel
• 20-minute walkable neighbourhood;
• Provision of green pedestrian and cycle lane connections; and
• Easy access to local services and facilities, including the proposed local centre within
the site.
Biodiversity Net Gain
• Delivery of at least 10% biodiversity net gain, with the potential to exceed this target
due to the size and arable nature of the site. Additionally, opportunities to enhance the
waterway will be explored to further improve biodiversity net gain; and
• Habitat creation and improvements to hedgerow and the tree stock.
Energy Efficiency and Towards Carbon Neutrality
• Delivery of energy efficient homes and potential use of renewable energy.
• Eliminate the use of gas boilers and utilisation of high-efficiency electric heating
systems such as heat pumps.
3.31 The Site would include for delivery of a 2FE Primary School, a small local centre
incorporating community facilities, public open space, play areas for children, including a
locally equipped area for play (LEAP), natural green and blue spaces and riverside. The Site
also provides an opportunity for a c.80 bed care facility. In addition, pedestrian and cycle
lanes would be provided throughout the Site to promote active travel, along with the
potential for a new river crossing to enable access to the town centre.
3.32 Mackenzie Miller Homes considers that the Site presents a logical location for residential
development, outside of the Green Belt, that would support the sustainable growth of
Shipston-on-Stour and strongly believes that SG17 should be allocated for housing
development in the SWLP to help address the SWC’s housing needs, as well as the unmet
need from the neighbouring authorities.

Yes

ID sylw: 108364

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

4.1 The Site was assessed in the SWC’s ‘Housing and Economic Land Availability Assessment
(2024)’ [HELAA]. HELAA under the Site References: 148 – Land at Fell Mill Farm,
Shipston and 747 – Land at Leasow Farm. Mackenzie Miller Homes welcomes the
recommendation for the Sites to remain in consideration for the SWLP.
4.2 The SWCs 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 commence development in the first 5 years of the plan period. 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.”
4.3 In this context, Mackenzie Miller Homes wishes to reaffirm the Site’s status as being
‘suitable, available and achievable’ and that Mackenzie Miller Homes Vision for the Site is
predicated upon evidence which ensures that there are no environmental or technical
constraints to the development of the Site.
4.4 Importantly, Mackenzie Miller Homes have the capability and expertise to deliver this
Vision for the Site and is committed to working constructively with the SWCs and local
stakeholders through the plan-making process. In this respect, Mackenzie Miller Homes is
a privately owned company that specialises in building design led, sustainable and
premium quality homes across The Home Counties. Mackenzie Miller Homes have control
over the land and are committed to direct delivery of new homes.
Timescales of Delivery
4.5 It is envisaged that the Site could be developed in the medium term in three phases:
• Phase 1 could provide c.272 homes to the northwest of the river Stour, providing main
access to the northern parcel. This phase could also integrate and strengthen the
existing PROW’s into the development.
• Phase 2 could provide c. 500 homes and establish development to the east of the river
providing access to this part of the site; primary and secondary access to the southern
parcel to access the development. This phase would also include the delivery of a local
centre and 2FE School; and
• Phase 3 – could infill the site to take the development up to 1,150 homes (this number
includes the proposed number of Phase 1 and Phase 2 homes) across the site. This
phase could include a new vehicle and /or pedestrian and cycle bridge across the river
at the narrow point linking Shipston with the development north and south.

Additionally, this phase would also include the delivery of a care facility and Riverside
Park.
4.6 It is envisaged that subject to the Site being allocated in a future Regulation 19 SWLP,
Mackenzie Miller Homes would seek to submit a planning application in advance of the
Examination in Public to assist the SWCs in demonstrating the deliverability of the
allocation to Inspectors.
4.7 Assuming the SWLP is adopted in line with the SWC’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.
4.8 In respect of the delivery trajectory, Mackenzie Miller Homes envisages the Site could be
delivered broadly in line with the below trajectory and deliver well within the SWLP plan
period:
Approach to achieving net zero
4.9 As mentioned above, Mackenzie Miller Homes’ 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 Mackenzie Miller Homes proposes to achieve this is set out in detail in the supporting
Vision Document (Appendix 1).
4.10 In summary, 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 linear Riverside Park.
4.11 When paired together 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 SWCs
in achieving Net Zero.
Mitigation of issues identified through the SA
4.12 Based on the SA conclusions, SG17 performs well against many of the SWC’s SA objectives,
set out in the ‘Interim Sustainability Appraisal of the South Warwickshire Local Plan
Regulation 18: Preferred Options Stage’.
4.13 However, as noted earlier in this document, it is considered that performance against
several of the SA Objectives would be enhanced through assessment of the likely mitigation
that would be delivered alongside development at SG17. Indeed, as stated within the SA:
“Mitigation has not been considered when ranking the SGLs, given the options requiring
less intervention are likely to be more sustainable choices.”
4.14 Mackenzie Miller Homes has set out below how the Site could mitigate against any of the
impacts identified within the SA and the corresponding likely assessment against the SA
Objectives:
4.15 It should be noted that further technical work can be provided to the SWCs 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.

Other

ID sylw: 108365

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

5.1 Mackenzie Miller Homes does not object to the SWCs exploring New Settlements to meet
some housing needs and acknowledges that the SWCs will require various sites to address
the LHN and contribute towards the unmet housing needs from the neighbouring areas.
Paragraph 77 of the NPPF states:
“The supply of large numbers of new homes can often be best achieved through planning
for larger scale development, such as new settlements or significant extensions to existing
villages and towns, provided they are well located and designed, and supported by the
necessary infrastructure and facilities (including a genuine choice of transport modes)..”
5.2 It is important to highlight that the NPPF is also clear that plans should be prepared
positively, in a way that is aspirational but deliverable (Para 16b), and should identify
specific, developable sites or broad locations for growth, for years 6-10 and, where possible,
for years 11-15 of the plan (Para 72b).
5.3 However, Mackenzie Miller Homes would like to highlight large-scale developments such as
New Settlements often take years to fully deliver and may not meet all needs within the plan
period. Paragraph 22 of the NPPF states:
“Strategic policies should look ahead over a minimum 15 year period from adoption, to
anticipate and respond to long-term requirements and opportunities, such as those
arising from major improvements in infrastructure. Where larger scale developments
such as new settlements or significant extensions to existing villages and towns form part
of the strategy for the area, policies should be set within a vision that looks further ahead
(at least 30 years), to take into account the likely timescale for delivery.” (Emphasis
Added).
5.4 The Councils must consider reasonable alternatives and be based on proportionate
evidence (Para 36b). It is considered that the Councils must evaluate alternative housing
distributions through the SA early on. It must also ensure a sufficient mix of sites that are
viable, available, and suitable (Para 69).
5.5 Furthermore, the Planning Practice Guidance [PPG] requires LPAs to show a reasonable
prospect that large-scale developments will come forward, including a realistic assessment
of development timelines and engagement with infrastructure providers to ensure
feasibility within the planned timescales (PPG ID: 61-060).
5.6 Given the above, Mackenzie Miller Homes would not object to the option of exploring
meeting some of the SWC’s needs through a New Settlement but would like to highlight to
the SWCs that sufficient evidence will need to be prepared in support of any future
allocation.
5.7 Notwithstanding this, Mackenzie Miller Homes believes that New Settlements should not
be the only option for meeting all of the SWLPs needs, as these types of developments take
many years to commence. Therefore, Mackenzie Miller Homes considers that SWCs should
use a mix of sites and sizes, including larger sites at different scales, within the SWLP area in sustainable locations to ensure that supply can come forward at different parts of the
plan period to meet the housing needs over the 2050 plan period. As such, it is considered
that larger sites such as land at Fell Mill and Leasow Farm should be allocated to help
meeting the LHN.

Other

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.

Other

ID sylw: 108367

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

7.1 In general, Mackenzie Miller Homes agrees with the Council’s proposed approach to
require developments to provide appropriate on- and off-site infrastructure and to make
contributions towards the delivery of infrastructure.
7.2 It is an appropriate approach for developments to alleviate their impacts and where
possible and necessary make contributions towards associated infrastructure. It will be
essential for the Council to prepare an Infrastructure Delivery Plan [IDP], which sets out
the necessary infrastructure to mitigate the proposed development allocations (especially
for any strategic developments and New Settlements) as the SWCs progress the SWLP.
7.3 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 35 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.” (Emphasis Added)
7.4 As such, it is critical that the emerging plan is clear through site-specific allocations the
level and type of infrastructure improvements that are necessary for each development
allocation.
7.5 Furthermore, the NPPF is also clear that planning policies should have regard to the
economic viability of sites (Para 68) and should not undermine the deliverability of the
Local Plan (Para 35). Planning policies should be underpinned by proportionate evidence
including a viability assessment that cumulatively tests the impact of infrastructure
requirements on the viability of any allocated sites. This should include any site-specific
infrastructure required to support the delivery of some sites, as well as any Community
Infrastructure Levy.

Yes

ID sylw: 108368

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

8.1 Mackenzie Miller Homes is supportive of protecting the Green Belt and generally supports
the Draft Policy Direction 7 – Green Belt. It should be noted that Mackenzie Miller Homes’
Site is not within the designated Green Belt.
8.2 While Green Belt land can offer a more sustainable location for development to promote
sustainable patterns, even when other greenfield land is available, the SWCs should also
consider sustainably located greenfield land, especially if it aligns with the proposed Spatial
Growth Strategy.
8.3 Mackenzie Miller Homes acknowledges that the SWLP may need to release Green Belt land
due to the significant housing needs of the SWCs under the new SM. It is apparent that
exceptional circumstances can be demonstrated, and Green Belt release should be
considered alongside brownfield and greenfield land. Nonetheless, the NPPF outlines a
'sequential approach' in Paragraph 147a,
“Before concluding that exceptional circumstances exist to justify changes to Green Belt
boundaries, the strategic policy-making authority should be able to demonstrate that it
has examined fully all other reasonable options for meeting its identified need for
development. This will be assessed through the examination of its strategic policies, which
will take into account the preceding paragraph and whether the strategy:
a makes as much use as possible of suitable brownfield sites and underutilised
land”
8.4 Therefore, Mackenzie Miller Homes strongly believes that the SWLP should direct growth
to Shipston and allocate Mackenzie Miller Homes’ Site in the SWLP, following the
'sequential approach' before releasing Green Belt land as per the relevant sections of the
NPPF.

Yes

ID sylw: 108369

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

9.1 Mackenzie Miller Homes agrees with the approach laid out in Draft Policy Direction 10 as
this is in line with Paragraph 63 of the NPPF which 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.
9.2 Additionally, 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.” As such, Mackenzie Miller Homes
agrees that the SWCs should have regard to the latest evidence in drafting policies relating
to housing tenure and type in due course, in accordance with the NPPF.
9.3 Furthermore, 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 is clear that:
9.4 “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.”
9.5 In Paragraph 72, the NPPF is also clear that planning policies should have regard to the
economic viability of sites. Paragraph 35 states that planning policies should not undermine
the deliverability of the Local Plan. Importantly, 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.
9.6 In this respect, it is recognised that the SWCs have not yet specified a proposed affordable
housing requirement. The PPG4 clearly states that the SWLP should aim to meet as much of
its identified affordable housing needs as possible, although it is not obligated to fulfil these
needs entirely.5 Therefore, it is crucial for the SWCs to test various requirements through
the Viability Assessment to ensure that the overall deliverability of the SWLP is not
compromised (Para 34). This is especially important for allocations within the Green Belt,
considering the NPPF’s ‘Golden Rules’ (Paras 67, 68, and 156a).
9.7 Nevertheless, Mackenzie Miller Homes 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. In Paragraph 82(d), the NPPF is clear that planning policies should be
flexible enough to adapt to unforeseen circumstances and changing economic conditions. Therefore, Mackenzie Miller Homes 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: 108370

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

10.1 Yes, Mackenzie Miller Homes is supportive of the SWC’s efforts to improve housing
standards by requiring developments to meet Nationally Described Space Standards
[NDSS]. However, it is considered that this requirement will need to be sufficiently
justified.
10.2 Footnote 51 of NPPF paragraph 135(f) states that policies may “make use of the nationally
described space standard, where the need for an internal space standard can be justified.”
10.3 Moreover, as noted above, Paragraph 32 of the NPPF makes it clear that plans should be
underpinned by relevant and up-to-date evidence that is adequate, proportionate and
focussed tightly on supporting and justifying the policies concerned. Furthermore,
Paragraph 72 of the NPPF is also clear that planning policies should have regard to the
economic viability of sites and Paragraph 35 states that they should not undermine the
deliverability of the Local Plan, which is also supported by the PPG.6
10.4 Mackenzie Miller Homes recognises that the PO’s supporting text states the SDC Housing
Strategy 2021 evidence log notes that poor space standards on units on developer-led s106
sites (for affordable housing) are an issue and that a further assessment is being undertaken
on the extent of non-compliance with NDSS and whether this is more prevalent for certain
types of residential development, alongside viability testing the NDSS requirement (Pg.62).
10.5 Given the above context, Mackenzie Miller Homes would suggest that the SWCs publish a
Topic Paper evidencing the need for NDSS, alongside a Viability Assessment that tests the
impact of policy requirements on the viability of sites allocated in the SWLP in accordance
with the NPPF and PPG in due course. This would be critical evidence to underpin the
SWLP’s proposed policy approach and will be necessary to ensure that the policy is found to
be sound.