Comment

Representation ID: 23080

Received: 11/10/2021

Respondent: Bromsgrove District Council

1. Bromsgrove District Council (BDC) welcomes the opportunity to comment on the Draft Black Country Plan (BCP). The BCP appears to be based around appropriate aims and objectives and provides a solid foundation on which to plan the future of the Black Country (BC) albeit BDC does have some reservations. BDC has reviewed the policies and proposals and has the following detailed comments to make.
Policy CSP1 – Development Strategy
2. The Council notes the development levels identified within policy CSP1 and the supporting text, in particular the 28,239 dwellings and 210 hectares of employment land to be accommodated outside of the plan area through the Duty to Cooperate.
3. The Council also note the comments made at para’s 3.23, 3.25 and 3.27 and would wish to make the following observations
3.23 National planning policy requires this unmet housing and employment land need to be provided for across the Housing Market Area, Functional Economic Market Area (FEMA) and other areas with which the Black Country has a physical or functional relationship.
3.25 The BCA recognise that this approach may only address a proportion of the housing and employment shortfall, as it is inappropriate and beyond the powers of the BCA to establish the limits of sustainable development in neighbouring authorities.
4. Whilst the requirements of the national guidance are acknowledged it is also accepted that the BCP cannot physically allocate development for the needs of the BC in other local authorities development plans. However the current strategy in the BCP appears to be a very hands off approach at this stage. It is accepted that para 3.24 identifies that the Black Country Authorities (BCA) have worked under the duty to cooperate and that para
3.26 commits the BCA to further engagement to find the most appropriate and sustainable locations for housing and employment growth. As it stands the draft plan provides no guidance to other local authorities on any requirement for accommodating unmet BC growth ,or any methodology for distributing the requirement between authorities, and only very limited information on where the growth should be located. To expect neighbouring authorities to consider whether its appropriate to provide growth for the BC with little or no guidance from the exporting authority falls short of what could be described as constructive engagement under the duty to cooperate.
5. Notwithstanding the above comments about the lack of direction the BCP plan gives on meeting the wider housing need at 3.25, para 3.27 then appears to suggest locations where the BCA are supportive of appropriate and sustainable locations for housing and employment growth which is suitable for the needs of the BC.
3.27 Reflecting the efforts of those neighbouring authorities who are supporting the delivery of the Black Country’s wider housing and employment land need, where it is shown to be desirable, appropriate, sustainable and deliverable the BCA will support their neighbours in bringing forward land for housing and employment that sits adjacent to the existing administrative boundaries, and will work in partnership to ensure infrastructure needs are met in full across administrative boundaries.’
6. BDC notes the findings of the various studies which form the evidence base supporting the BCP. In particular the findings of the Black Country Green Belt Study, Landscape Sensitivity Assessment and Historic Landscape Characterisation Study. The outcomes of these studies which BDC has reviewed and has no reason to dispute at this stage, have effectively ruled out development on the southern edge of the BC in Dudley Metropolitan Borough adjacent to Bromsgrove District, With the exception of sites DUH206,207 and 209. The ruling out of this land means that the administrative boundary between Bromsgrove and the BC is not able to accommodate appropriate, sustainable and deliverable development, therefore the ability of BDC to accommodate the needs of the BC is critically damaged. BDC will continue to engage with all local authorities under the Duty to Cooperate but the Council is now struggling to see how it can now help meet the needs of the BC other than in locations which are not supported by the draft Black Country Plan.