Object

Representation ID: 43816

Received: 11/10/2021

Respondent: HIMOR Group

Agent: Emery Planning

12. Summary and conclusions
12.1 We do not consider that the plan as drafted is sound for the following reasons:

The plan fails to meet local housing need, which results in significant social and
economic adverse impacts.

Black Country. In fact, the starting point for the Black Country should be to meet its
own needs and et needs.
There are no firm agreements with neighbouring authorities to meet the identified
unmet needs.
The identified housing land supply has been exaggerated. A significant shortfall exists
even against the current artificially reduced housing requirement.
Continued reliance upon a supply mainly comprising brownfield sites in the urban area
will not deliver enough affordable housing to meet the identified needs, and it will not
address the need for specific types of housing, in particular family housing.

justified. The land mainly comprises improved grassland of low ecological value.
The application of the site selection methodology is flawed. Impacts are significantly
over-stated, particularly in relation to landscape and Green Belt harm, seemingly to
justify not meeting the local housing need in full. The methodology has also been
applied inconsistently between draft allocations and omission sites.
12.2 Additional site allocations are needed to address the identified issues of soundness.

12.3 The proposed allocation of can contribute to meeting the identified
development needs of the Black Country in a highly accessible location. The site could also
deliver a new, state-of-the-art replacement school for Aldridge High School to secure its long-
term future. This is a significant, site-specific benefit which amounts to exceptional circumstances
justifying the release of the site from the Green Belt. As addressed within these representations,
the site can be delivered without any significant adverse harm to the Green Belt, the landscape
or ecology interests.

12.4 We are currently in the process of refining the proposals for the site. We intend to prepare and
submit a development framework document, including more detailed proposals for the
replacement school and the findings technical information, in the coming months.


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13. Appendices [supporting evidence: see attachments]
EP1. GBBCHMA housing need and land supply review
EP2. Black Country housing need and land supply critique
EP3. Site location and concept masterplan
EP4. Ecological walk over survey
EP5. Secretary of State appeal decision (Effingham)
EP6. Secretary of State appeal decision (Seashell Trust)