Comment

Representation ID: 23060

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy HOU1 – Delivering Sustainable Housing Growth
Point 1(a) states that the plan will deliver at least 47,837 dwellings. We understand that all of the BC housing needs may not be able to be delivered within the plan area, however we consider that there is capacity for the plan area can accommodate additional growth through further Green Belt release to reduce the amount of dwellings that need to be accommodated by the HMA. The Duty to Cooperate Statement (July 2021) states that discussions to date have identified that circa 14,750 dwellings could be accommodated by adjacent authorities. Although we acknowledge that there could be capacity to increase this figure, this still leaves a significant shortfall (circa 14,000 dwellings). We support the proposed allocation of WSA9 and consider that there are exceptional circumstances that justify the release of the Green Belt sites in the plan.
In addition to the BC housing need and shortfall there is a wider HMA shortfall which has yet to be confirmed. Although the Draft BCP has not gone into detail at this stage on the wider HMA position. The HMA authorities have published three position statements to support their local plan reviews. The most recent statement was published in September 2020 (‘PS3’) and states that the 37,900 dwelling shortfall (from Birmingham’s housing shortfall not including the BCA shortfall) has decreased to just 2,597 dwellings. PS3 is now being relied upon by the HMA authorities to support their local plan reviews. We do not consider that this approach is sound given that:
- The PS3 only covers the plan period up to 2031 when the local plan reviews, including the BCA plan, are working beyond this period;
- The PS3 does not acknowledge the fundamental changes in the calculation of housing need since the adoption of the Birmingham Development Plan when the 37,900 dwelling shortfall was confirmed which has seen the Birmingham and Wolverhampton minimum housing need increase by 35%;
- The PS3 does not reflect the standard method housing figures and has no regard to other situations where the housing requirement should be higher than the standard method e.g. economic ambitions and affordable housing need;
- The PS3 has over-estimated housing land supply particularly in regards to strategic allocations in Birmingham (Langley site) and Stratford-on-Avon (Long Marston Airfield site).
- The 37,900 dwelling figure quoted in the PS3 also does not consider the BCA shortfall or any shortfall associated with Birmingham with the 35% uplift, and
- The data used to support the findings of PS3 has neither been made readily available nor tested at an Examination yet.
In light of the above, we consider that the HMA housing shortfall is greater than is currently being suggested by the HMA authorities. The NPPF states that in order to be ‘effective’ a plan should deal with cross-boundary strategic matters rather than deferring them to the next plan period (paragraph 35). Therefore, given the BCA has determined that Green Belt release is already required to meet current housing needs (which we consider is significantly lower than it should be), it is accordingly expected that additional Green Belt release could be required to meet the development needs of the District within and beyond the plan period.
St Phillips have worked collaboratively with Taylor Wimpey (adjacent landowner to the south) to produce a combined masterplan to show the potential for community infrastructure delivery across a wider strategic development site, including the land to the west of Site WSA9 (Illustrative Masterplan attached with this submission). This site has the potential to deliver circa 800 dwellings, land for a new school, local centre/health facility and significant public open space including a country park. This wider proposal may also be of a scale that could support a new/improved bus service on Chester Road which would enhance the sustainability credentials of the existing settlement. The scale of the combined proposals gives rise to a more comprehensive opportunity than the constrained and fragmented proposition contained in the draft plan at present and would allow for the inclusion of significant community infrastructure.