Comment

Representation ID: 23322

Received: 11/10/2021

Respondent: Miller Homes

Land south of Holly Lane, Landywood
This representation has been prepared and submitted by Miller Homes Limited (“Miller”) and concerns Policy CSP1 “Development Strategy, and accompanying Table 2, of the Draft Black Country Plan (DBCP) and the significant unmet housing need in the period up to 2039.

The purpose of this representation is to highlight the availability of land south of Holly Lane, Landywood which provides a highly sustainable option to deliver much needed housing that can contribute towards the Black Country’s significant shortfall.

The land is identified and proposed development presented through the Vision Document at Appendix 1 (see attachment). Through the Local Plan Review, South Staffordshire is proposing that part of the site be removed from the Green Belt and allocated to deliver a minimum of 84 dwellings. However, Miller contest that the whole site, which could deliver in the region of 350 dwellings, remains suitable and could make a valuable contribution towards addressing the acute housing need in the Black Country.

Policy CSP1 and Table 2
Policy CSP1 sets out the proposed Development Strategy for the Black Country including the scale and distribution of new development and proposes to deliver “at least 47,837” dwellings over the period to 2039. Miller contends that to deliver this quantum of housing will require land to be released from the Green Belt. This scale of housing provision falls significantly short of the sub-region’s minimum Local Housing Need, by at least 28,239 dwellings.
The unmet need is to be “exported” to the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA), or other authorities, as presented in Table 2, and this will be achieved through the Duty to Co-operate. Paragraphs 3.24 and 3.26 state that the Black Country Authorities (BCA) have, and will continue to work constructively with neighbouring authorities to deliver the housing shortfall. We are aware that formal requests for assistance have been raised with the other HMA authorities, as well as wider local authorities.

Miller supports the positive and proactive approach adopted by the BCA to seek assistance and secure commitments to the significant housing shortfall through preparation of the BCP, rather than seeking to defer this strategic cross-boundary issue post-adoption. It is noted that a number of local authorities have already pledged contributions, albeit there will remain a considerable “gap”. South Staffordshire Council’s Draft Preferred Options Plan (September 2021) is proposing to contribute 4,000 dwellings towards the Black Country shortfall “…in order to ensure that that emerging and existing shortfalls from the conurbation are addressed in a genuinely sustainable manner” (paragraph 4.12).
Miller will be making representations to the emerging South Staffordshire Local Plan Review to request an increased housing requirement so that an even greater contribution can be made to the Black Country.

The Opportunity at Landywood
Whilst part of the site has been identified through the South Staffordshire Local Plan Review, Miller contends that the entirety of the controlled land to the south of Holly Lane is sustainable and deliverable and should therefore be released from the Green Belt to meet needs to 2038. Through allocating the entirety of the site, or a larger proportion of it, the site could make a greater contribution to the Black Country housing shortfall to 2039.

We hope this representation provides helpful insight into the availability of sustainable land at Landywood which can deliver c.350 dwellings and thereby further contribute towards the Black Country’s housing shortfall.