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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.