Comment

Representation ID: 23218

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Overspill

Notwithstanding the concerns about the capacity of the urban area in Black Country to deliver the development needs identified within the plan period and an additional capacity that might be identified in the Green Belt, it is evident that the overspill is going to be significant in terms of housing and employment land.

HD acknowledge that the BCP states this will be delivered through the duty to cooperate, however, at the draft plan stage we would have expected a clearer understanding on what this means and who is potential taking what in order to demonstrate the plan is positively prepared in accordance with the provisions of the Framework, which states:

“(a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs 21 ; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;” (our emphasis).

The evidence is clear that Birmingham and South Staffordshire have the strong functional and geographic relationship, but they Birmingham is not able to assist as it cannot meet its own needs. If the development needs are to be met in a location that relates to the Black Country, rather than the other side of the conurbation, South Staffordshire will have to take a significant proportion of the overspill.

South Staffordshire has agreed to test 4000 dwellings at this time, with employment land to be determined. By any measure, this is nowhere enough. This is not to take away from the positive working relationship between the BCAs and South Staffordshire, which in many ways is to be commended. Instead, this is a product of the vast numbers we are talking about.

HD, therefore, strongly encourages the BCAs to reopen these discussions with South
Staffordshire to see if additional capacity can be agreed.

HD is promoting a site immediately adjacent to Wall Heath in South Staffordshire. The site adjoins the Black Country on two sides. It is available and deliverable. This could add to the number of houses in South Staffordshire and HD will be submitting a vision document to South Staffordshire consultation later this year to demonstrate how this site could come forward.