Object

Representation ID: 1727

Received: 08/09/2017

Respondent: Jay Farm Homes Limited and Lawnswood Homes Limited

Agent: SLR Consulting

Answer: No

Detail: Whilst the evidence set out in Table 1 is comprehensive, SLR would question whether the content and findings of these documents would need to be updated following the completion of the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study which was commenced in March 2017 and due to be completed in September 2017. This report could ultimately require for the updating of the following key evidence base documents relating to housing in the sub-region:
Greater Birmingham and Solihull LEP / Black Country Authorities Strategic Housing Needs Study (SHNS) Stage 3 Report (PBA) - completed August 2015;
Strategic Housing Market Assessment for Black Country and South Staffordshire including Gypsy andTraveller needs (PBA) - completed February 2017;
Strategic Housing Land Availability Assessments for Dudley, Sandwell, Walsall and Wolverhampton (Local authorities) - completed 2016/2017; and
Housing Background Report (Local authorities) - completed May 2017.

In addition, SLR would suggest that a comprehensive Black Country Green Belt Review needs to take place, not only reviewing Green Belt within the Black Country sub-region but also reviewing Green Belt land within the adjoining authority areas such as South Staffordshire District Council. It is understood that this document is currently being scoped with an intention to be completed by mid-2018. SLR will seek to submit further representations to this document on behalf of our clients at the appropriate time.

As stated, it is important that the key documents are updated when required and the review is based on up-to -date and robust evidence. With this in mind, SLR would encourage the Black Country to work with adjoining local authorities to ensure that a comprehensive and coherent approach is taken to the Call for Sites, any Strategic Housing Land Availability Assessments (SHLAAs) and Green Belt Reviews going forward.
Without this housing need and delivery will not be met and the existing shortfall will continue to increase, leading to pressure to release unallocated land throughout the Black Country region. SLR therefore urges the Black Country to allocate and safeguard sufficient sites for housing needs beyond the forthcoming plan period.