Comment

Representation ID: 2946

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March 2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change in plan making. 2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery. 2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed, housing is one of the Plan's eight priority actions. Clearly the BCCS Review needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP. 2.4 The adopted BCCS did not release any Green Belt land for development. In stark contrast, the emerging BCCS proposes the release of Green Belt land to deliver a minimum of 14,270 dwellings in order to meet the Black Country's needs. This represents a significant departure from the approach of the adopted BCCS. 2.5 To date the BCCS has failed to meet the Black Country's needs since 2006. As at 31 March 2016 there is a shortfall of 3,039 dwellings against the stepped housing delivery trajectory. In Wolverhampton alone there is a shortfall of 1,396 dwellings. Across the area there is a shortfall in employment land of 57 ha and a shortfall in office space in strategic locations of 191,756 sqm. 2.6 Therefore a full review of the BCCS is essential to ensure: * The plan is up to date and is prepared in the current planning context, and reflects the area's current needs (as opposed to those identified in the now revoked WMRSS). * All policies and objectives of the emerging BCCS Review are consistent with national planning policy. * It comprises a strategy which will deliver against the Black Country's identified needs, and one that is effective, and measurably so, when compared to the shortcoming of the adopted BCCS. 2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.