Comment

Representation ID: 22187

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

Policy CSP2 – The Strategic Centres and Core Growth Regeneration Areas

We generally support the objective of directing development to the Strategic Centres and Core Growth Regeneration Areas. Development should be directed to locations where it is most needed and that are best able to accommodate it in terms of accessibility to services and facilities. The Strategic Centres and Core Growth Regeneration Areas are suitable for higher density development where new residents would have the greatest access to commercial, cultural, leisure, entertainment and community facilities, as well as employment opportunities.

However, notwithstanding the focus on Strategic Centres and the Core Growth Regeneration Areas, it is clear that there is insufficient land available in these areas for the housing requirement to be met. Indeed, the emerging Plan acknowledges that Green Belt land release is required within the Black Country. Even with the Green Belt land release that is proposed Policy CSP1 advises that a housing shortfall of a minimum 28,239 dwellings exists (as detailed in our response to Policy CSP1 we believe this is an underestimated) that needs to be delivered in other Local Authority Areas within the HMA.

As of yet the neighbouring authorities have not agreed an approach to the distribution of the housing shortfall or identified allocations in their emerging Plans that could meet this shortfall, in combination with the shortfall arising from Birmingham City. There is no certainty that the housing shortfall can be met on sustainable and deliverable sites. It is, therefore, essential that the emerging Black Country Plan allocates as many sustainable and sustainable sites for development to help ensure that the overall housing requirement is met. As detailed in these representations, the Club has surplus land in its control that should be allocated for development to meet the housing requirement.