Support

Representation ID: 1730

Received: 08/09/2017

Respondent: Jay Farm Homes Limited and Lawnswood Homes Limited

Agent: SLR Consulting

Birmingham's needs up until 2031 that cannot be accommodated within the City, even allowing for the proposals in the Plan to utilise land within the Green Belt (paragraph 3.10). The Strategic Housing Network Study (SHNS, completed in 2015) considered scenarios for distributing this housing shortfall. The study concluded that the supply of brownfield land across the HMA is insufficient and that the majority of this shortfall will need to be met on greenfield sites, including green belt outside Birmingham's administrative area (paragraph 3.11).

SLR supports the premise that through the duty to cooperate there is a mechanism in place to explore new housing provision beyond the HMA where there are clear migration and commuting links. Notwithstanding, as detailed within paragraph 3.12, it is clear that South Staffordshire provides a clear opportunity to accommodate some of this shortfall given that it is a logical sub-market of the HMA. SLR would, therefore, encourage the Black Country to actively work with South Staffordshire District Council to consider whether there are opportunities for cross boundary working/allocation of housing sites.

SLR supports the findings of the Strategic Housing Market Assessment (SHMA) completed in 2017 which identifies that the Objectively Assessed Housing Need ('OAN') for the Black Country over the period 2014-36 is 78,190 homes. SLR also supports that the OAN has made an allowance for a national backlog which has arisen over the period 2011-14 where the annual need for housing was greater than that planned for in the existing Core Strategy.

It is noted that paragraph 3.13 identifies that "The SHMA may be updated during the review as and when new Government projections and guidance become available and housing supply information changes". SLR encourages the authority to undertake this update as swiftly as possible following publication of such information.

Given the above, SLR also considers that a comprehensive review of the Green Belt should be undertaken for both the Black Country area and the adjoining local authorities within the HMA to ensure that sufficient housing sites are either allocated or safeguarded for both the forthcoming and subsequent plan periods. This is especially pertinent given that the SHMA has already accounted for a significant backlog and that these figures are likely to be increased once the Government projections and guidance are updated.

In this respect, SLR duly requests that the Black Country Core Strategy Review consider our Client's site for suitability for release from the Green Belt and either allocation in the short term or a longer term safeguarding. The site can either be brought forward as a smaller independent site or, if the adjoining County Council land is released, as a strategic allocation which could go toward meeting the housing need for the HMA.

With regard to any Green Belt Review, this should be comprehensive in its remit, covering both the Black Country area and Green Belt areas immediately adjoining the settlement boundaries. On this point, it should be noted that the NPPF states that when local authorities are reviewing established Green Belt boundaries they should take account of the need to promote sustainable patterns of development, channelling development towards urban areas inside the Green Belt boundary (NPPF paragraph 84). Indeed, paragraph 85 of the NPPF identifies that when defining boundaries, local planning authorities should:
ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;
not include land which it is unnecessary to keep permanently open;
where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the
Green Belt, in order to meet longer-term development needs stretching well beyond the plan period;
make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a
Local Plan review which proposes the development;
satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and
define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We would encourage any comprehensive Green Belt Review to accord with the thrust of these criteria defined within paragraph 85 of the NPPF.

South Staffordshire District Council have, to date, excluded urban/conurbation edge sites from consideration for release through their Partial Green Belt Review. We consider that the Black Country area should be encouraging/requiring the need for these sites to be included for consideration within a more comprehensive
Green Belt Review as they could be more located in closer proximity to infrastructure and more sustainable than other sites further afield.