Object

Representation ID: 44792

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

The relationship with the need for employment land and reliance on the SHLAA

4.16 The BCP evidence base26 concludes there is a gap (shortfall) of 140.3 ha against the demand requirement for employment sites in the Black Country area. The Councils state this will need to be addressed through ongoing Duty to Co-operate engagement with neighbouring local authorities.

4.17 There are a number of sources of the Councils’ housing land supply which are proposed on existing vacant or occupied employment land. The NPPF states that a sufficient supply of employment sites should be provided as well as housing. The NPPF is also clear at paragraph 81 that planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. It states that significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for
development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future.

4.18 In this way, the reliance on occupied employment sites to deliver housing instead directly contradicts the intention of national policy to support economic growth and productivity.

4.19 The NPPF requires there to be a realistic prospect that a site will be available and could be viably developed at the point envisaged. The fact that many sites in the Councils’ trajectory are likely to be in demand for employment land, given the shortfall of 140.3ha identified, increases doubt that they will be developed for housing at the point envisaged.

4.20 The NPPF also states at paragraph 68 that strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.

4.21 Having reviewed the four SHLAAs, which are a key source in determination of the urban capacity in the Black Country, we have concerns with the approach taken, and any plan making decisions based upon them. The SHLAAs state that:

“Only where a site has a realistically implementable permission for an alternative, non- housing use will it be removed from the list of SHLAA sites”

4.22 This does not account for the likely high number of sites which may have potential for alternative, non-housing uses, but that simply do not benefit from an implementable permission. It could be argued that based on the SHLAA conclusions, these sites are as much possible employment sites as they are housing sites.

4.23 If this is the approach taken to understanding the stock of available housing sites, it is vital that reasonable and realistic planning judgement is then applied when relying on their delivery to meet requirements in the plan period.