Comment

Representation ID: 21475

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy CSP1 – Development Strategy

2.1. Policy CSP1 provides the proposed Development Strategy for the emerging Plan, identifying the need to deliver at least 47,837 homes. It identifies how this is to be delivered, which includes delivering the majority of development in the existing urban area; focusing growth and regeneration into the Growth Network and Strategic Centres and Regeneration Areas; as well as through a number of Neighbourhood Growth Areas in highly sustainable locations on the edge of the urban area.

2.2. The housing number proposed in Policy CSP1 however establishes that the Plan is not intending to meet its housing numbers in full, as the supporting text explains there will be a shortfall between the housing target and the local housing need of 28,239 homes. It is envisaged by the Black Country Authorities that this shortfall will be met through the Duty to Co-Operate.

2.3. As part of the Evidence Base for the Regulation 18 Consultation, a Duty to Cooperate Statement has been published. This details the outcome of initial attempts by the Black Country Authorities to engage with neighbouring authorities, and outlines the emerging ‘offers’ to meet unmet housing needs in the Greater Birmingham and Black Country Housing Market Area (GBBCHMA). Whilst this emerging Plan is still at an early stage of preparation, it is a concern that the ‘offers’ that have been made so far totals 8,000 homes, some of which would be contributing to unmet needs in Birmingham as well as the Black Country. Therefore a substantial shortfall is apparent between the local housing need figure for the Black Country and the amount of housing that is proposed to be delivered either within the Black Country Plan Area or neighbouring authority areas. It is unclear how this shortfall will be met.

2.4. Notwithstanding the efforts that have been made, the emerging Plan should recognise that the Duty to Co-Operate has been diminished by the Government, following the publication of the revised National Planning Policy Framework in 2018 and the Planning for the Future White Paper in 2020, with the latter proposing to abolish the Duty entirely without identifying what would replace it. Whilst previously, the Framework required authorities to work collaboratively with other bodies to meet development requirements which cannot be wholly met within their own areas, this requirement has been watered down in later revisions of the Framework. Authorities are still required to prepare and maintain Statements of Common Ground documenting cross-boundary matters and progress in cooperating to address these, as per Paragraph 27 of the 2021 version of the Framework. However, there is no longer a requirement in the Planning Practice Guidance for cooperation to produce effective and deliverable policies on strategic cross boundary matters, and instead bodies are required ‘to engage constructively, actively and on an ongoing basis to maximise the effectiveness of local plan preparation’. It is therefore considered that the emerging Black Country Plan should not be reliant on neighbouring authorities to deliver approximately one-third of the housing need for the Plan. There is no robust evidence that this level of housing need can be delivered by neighbouring authorities, or that there is a mechanism to ensure that this is achieved.