Comment

Representation ID: 2963

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.87 The NPPF is clear that local planning authorities should have fully explored all available options for delivering their housing needs within their own administrative boundaries before considering exporting growth to neighbouring authorities or the wider HMA. Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given this exercise had not been undertaken. As such this option should only be considered as a last resort. 2.88 It is also important to recognise that following the adoption of the Birmingham Development Plan there is an acknowledged shortfall of housing of approximately 38,000 homes across the Greater Birmingham HMA, the majority of which is a direct consequence of Birmingham's failure to accommodate its own needs in full. To date, whilst a number of emerging plans have confirmed the inclusion of additional provision to accommodate a proportion of this unmet needs the full scale of the unmet need has not been accounted for. The I&O Report references a commitment to test the accommodation of an extra 3,000 homes up to 2031 beyond local need to help address the wider HMA shortfall. Any attempt by the Black Country authorities to 'export' further unmet housing needs will compound the uncertainties associated with ensuring that needs are met in full across the HMA in the immediate term in particular. 2.89 In this context the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries, and therefore should fully consider the prospect of delivering up to 1,000 new dwelling at Pennwood as illustrated in Development Option 2 of the enclosed Vision Document.