Comment

Representation ID: 23344

Received: 11/10/2021

Respondent: Miller Homes

Lichfield Road, Burntwood
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 at Lichfield Road, Burntwood, 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). The site has not been identified for development within Lichfield’s Draft Submission Local Plan. However, Miller contest that the site, which could deliver in the region of 300 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”. Lichfield’s Proposed Submission Local Plan (July 2021) is proposing to contribute 2,665 dwellings towards the Black Country shortfall (paragraph 4.22) though no explanation is given as to how this number has been calculated. Of concern is that the contribution this now planned for is some 1,835 homes lower than the contribution (4,500) suggested at the Preferred Options stage of the plan.

Miller has submitted representations to Lichfield’s Draft Submission Plan which raise significant concerns with the plan’s soundness and, more specifically the plan’s spatial strategy, to request an increased housing requirement so that an even greater contribution can be made to the Black Country and raise concern over the limited quantum of growth directed towards Burntwood, a Tier 2 settlement and highly sustainable location.

The opportunity at Burntwood
Miller contends that land at Lichfield Road, Burntwood is sustainable and deliverable and should therefore be released from the Green Belt and form a residential allocation in the Lichfield Local Plan to meet needs to 2040. Such an allocation could make a further significant contribution to the Black Country housing shortfall to 2039.

We hope this representation provides helpful insight into the availability of sustainable land at Burntwood which can deliver c.300 dwellings and thereby further contribute towards the Black Country’s housing shortfall.

We would welcome the opportunity to discuss the site and emerging proposals with the BCA following the close of the Regulation 18 consultation but please do not hesitate to contact me in the meantime should you require further information.