Draft Black Country Plan

Comment

Representation ID: 23456

Received: 11/10/2021

Respondent: Miller Homes Ltd

Agent: Turley Assocs

Turley is instructed to submit a representation on behalf of Miller Homes Ltd (“Miller”) to Policy CSP1
“Development Strategy”, and accompanying Table 2, of the Draft Black Country Plan (BCP), in relation to
the significant unmet housing need in the period to 2039.
This representation highlights the availability of a significant area of land within Miller’s control at Shifnal
(Shropshire), which provides a highly sustainable option to deliver a community of c.1,300 dwellings to
meet Shropshire’s own housing needs but which could also contribute towards the Black Country’s
identified housing shortfall. With all of this land being controlled by a national housebuilder, delivery of
this sustainable community would be swift.
The Miller land is identified on the plan attached as Appendix 1 (see attachment), and is proposed to be removed from the Green Belt and “safeguarded” to meet housing needs beyond 2038 in the submitted Shropshire Local Plan Review (LPR). However, Miller are promoting this land for allocation so that it can meet needs to
2038, as explained below.
Policy CSP1 and Table 2
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 to 2039. This will
require Green Belt release given the capacity of the urban area. This scale of housing provision falls well
short of the sub-region’s minimum Local Housing Need, by at least 28,239 dwellings. We have made
separate representations to the BCP which question the soundness of certain components of the
assumed supply so the already significant shortfall has the potential to grow even further.

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”. Shropshire Council’s
submitted LPR (3 September 2021) is proposing to contribute 1,500 dwellings towards the Black Country
shortfall which “…responds to the functional relationship between the two areas” (paragraph 3.7).
Miller has made representations to the submitted Shropshire LPR to request an increased housing
requirement so that an even greater contribution can be made to the Black Country, given Shropshire’s
connections to the housing and economic markets through sustainable transport linkages such as railway
corridors and the M54 Motorway.
The opportunity at Shifnal
Shifnal has a particularly strong functional relationship with the Black Country, benefitting from a railway
station with hourly services to Wolverhampton and Birmingham, as well as immediate access to M54
Junction 3. 18% of Shifnal residents work in the GBBCHMA (Census 2011).
Whilst the Shropshire LPR recognises the sustainable credentials of Shifnal and proposes it is the focus
for growth in the regionally and nationally significant M54/A5 “Strategic Corridor” (including allocation of
a strategic employment site (SHF018)), housing development is restricted to only 300 new dwellings to
2038, beyond completions and existing commitments.
No new Green Belt releases are therefore proposed at Shifnal to deliver housing before 2038. Instead,
Green Belt is proposed to be “safeguarded” to meet housing needs beyond 2038. This includes 65ha of
land controlled by Miller (SHF029 and SHF015; Policies Map extract at Appendix 2) which Shropshire
Council propose will form a longer term “strategic housing extension capable of creating a new
neighbourhood” (paragraph 2.215). It is capable of delivering a sustainable community of c. 1,300
dwellings, as presented on the Illustrative Masterplan at Appendix 3.
This land is sustainable and deliverable and should therefore be “elevated” from safeguarded land to
form a residential allocation in the Shropshire LPR to meet the County’s needs to 2038. However, such
an allocation could also assist in making a contribution to the Black Country housing shortfall over this
period. With the land being controlled exclusively by a national housebuilder, the sustainable community
can be delivered swiftly.
We hope this representation provides helpful insight into the availability of sustainable land at Shifnal
which is already proposed for Green Belt release and which can deliver c.1,300 dwellings to meet
Shropshire’s housing needs but which is also ideally placed to contribute towards the Black Country’s
housing shortfall.

Comment

Representation ID: 23457

Received: 11/10/2021

Respondent: Miller Homes Ltd

Agent: Turley Assocs

Turley is instructed to submit a representation on behalf of Miller Homes Ltd (“Miller”) to Policy CSP1
“Development Strategy”, and accompanying Table 2, of the Draft Black Country Plan (BCP), in relation to
the significant unmet housing need in the period to 2039.
This representation highlights the availability of a significant area of land within Miller’s control at Shifnal
(Shropshire), which provides a highly sustainable option to deliver a community of c.1,300 dwellings to
meet Shropshire’s own housing needs but which could also contribute towards the Black Country’s
identified housing shortfall. With all of this land being controlled by a national housebuilder, delivery of
this sustainable community would be swift.
The Miller land is identified on the plan attached as Appendix 1 (see attachment), and is proposed to be removed from the Green Belt and “safeguarded” to meet housing needs beyond 2038 in the submitted Shropshire Local Plan Review (LPR). However, Miller are promoting this land for allocation so that it can meet needs to
2038, as explained below.
Policy CSP1 and Table 2
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 to 2039. This will
require Green Belt release given the capacity of the urban area. This scale of housing provision falls well
short of the sub-region’s minimum Local Housing Need, by at least 28,239 dwellings. We have made
separate representations to the BCP which question the soundness of certain components of the
assumed supply so the already significant shortfall has the potential to grow even further.

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”. Shropshire Council’s
submitted LPR (3 September 2021) is proposing to contribute 1,500 dwellings towards the Black Country
shortfall which “…responds to the functional relationship between the two areas” (paragraph 3.7).
Miller has made representations to the submitted Shropshire LPR to request an increased housing
requirement so that an even greater contribution can be made to the Black Country, given Shropshire’s
connections to the housing and economic markets through sustainable transport linkages such as railway
corridors and the M54 Motorway.
The opportunity at Shifnal
Shifnal has a particularly strong functional relationship with the Black Country, benefitting from a railway
station with hourly services to Wolverhampton and Birmingham, as well as immediate access to M54
Junction 3. 18% of Shifnal residents work in the GBBCHMA (Census 2011).
Whilst the Shropshire LPR recognises the sustainable credentials of Shifnal and proposes it is the focus
for growth in the regionally and nationally significant M54/A5 “Strategic Corridor” (including allocation of
a strategic employment site (SHF018)), housing development is restricted to only 300 new dwellings to
2038, beyond completions and existing commitments.
No new Green Belt releases are therefore proposed at Shifnal to deliver housing before 2038. Instead,
Green Belt is proposed to be “safeguarded” to meet housing needs beyond 2038. This includes 65ha of
land controlled by Miller (SHF029 and SHF015; Policies Map extract at Appendix 2) which Shropshire
Council propose will form a longer term “strategic housing extension capable of creating a new
neighbourhood” (paragraph 2.215). It is capable of delivering a sustainable community of c. 1,300
dwellings, as presented on the Illustrative Masterplan at Appendix 3.
This land is sustainable and deliverable and should therefore be “elevated” from safeguarded land to
form a residential allocation in the Shropshire LPR to meet the County’s needs to 2038. However, such
an allocation could also assist in making a contribution to the Black Country housing shortfall over this
period. With the land being controlled exclusively by a national housebuilder, the sustainable community
can be delivered swiftly.
We hope this representation provides helpful insight into the availability of sustainable land at Shifnal
which is already proposed for Green Belt release and which can deliver c.1,300 dwellings to meet
Shropshire’s housing needs but which is also ideally placed to contribute towards the Black Country’s
housing shortfall.

Comment

Representation ID: 23458

Received: 11/10/2021

Respondent: Miller Homes Ltd

Agent: Turley Assocs

Turley is instructed to submit a representation on behalf of Miller Homes Ltd (“Miller”) to Policy CSP1
“Development Strategy”, and accompanying Table 2, of the Draft Black Country Plan (BCP), in relation to
the significant unmet housing need in the period to 2039.
This representation highlights the availability of a significant area of land within Miller’s control at Shifnal
(Shropshire), which provides a highly sustainable option to deliver a community of c.1,300 dwellings to
meet Shropshire’s own housing needs but which could also contribute towards the Black Country’s
identified housing shortfall. With all of this land being controlled by a national housebuilder, delivery of
this sustainable community would be swift.
The Miller land is identified on the plan attached as Appendix 1 (see attachment), and is proposed to be removed from the Green Belt and “safeguarded” to meet housing needs beyond 2038 in the submitted Shropshire Local Plan Review (LPR). However, Miller are promoting this land for allocation so that it can meet needs to
2038, as explained below.
Policy CSP1 and Table 2
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 to 2039. This will
require Green Belt release given the capacity of the urban area. This scale of housing provision falls well
short of the sub-region’s minimum Local Housing Need, by at least 28,239 dwellings. We have made
separate representations to the BCP which question the soundness of certain components of the
assumed supply so the already significant shortfall has the potential to grow even further.

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”. Shropshire Council’s
submitted LPR (3 September 2021) is proposing to contribute 1,500 dwellings towards the Black Country
shortfall which “…responds to the functional relationship between the two areas” (paragraph 3.7).
Miller has made representations to the submitted Shropshire LPR to request an increased housing
requirement so that an even greater contribution can be made to the Black Country, given Shropshire’s
connections to the housing and economic markets through sustainable transport linkages such as railway
corridors and the M54 Motorway.
The opportunity at Shifnal
Shifnal has a particularly strong functional relationship with the Black Country, benefitting from a railway
station with hourly services to Wolverhampton and Birmingham, as well as immediate access to M54
Junction 3. 18% of Shifnal residents work in the GBBCHMA (Census 2011).
Whilst the Shropshire LPR recognises the sustainable credentials of Shifnal and proposes it is the focus
for growth in the regionally and nationally significant M54/A5 “Strategic Corridor” (including allocation of
a strategic employment site (SHF018)), housing development is restricted to only 300 new dwellings to
2038, beyond completions and existing commitments.
No new Green Belt releases are therefore proposed at Shifnal to deliver housing before 2038. Instead,
Green Belt is proposed to be “safeguarded” to meet housing needs beyond 2038. This includes 65ha of
land controlled by Miller (SHF029 and SHF015; Policies Map extract at Appendix 2) which Shropshire
Council propose will form a longer term “strategic housing extension capable of creating a new
neighbourhood” (paragraph 2.215). It is capable of delivering a sustainable community of c. 1,300
dwellings, as presented on the Illustrative Masterplan at Appendix 3.
This land is sustainable and deliverable and should therefore be “elevated” from safeguarded land to
form a residential allocation in the Shropshire LPR to meet the County’s needs to 2038. However, such
an allocation could also assist in making a contribution to the Black Country housing shortfall over this
period. With the land being controlled exclusively by a national housebuilder, the sustainable community
can be delivered swiftly.
We hope this representation provides helpful insight into the availability of sustainable land at Shifnal
which is already proposed for Green Belt release and which can deliver c.1,300 dwellings to meet
Shropshire’s housing needs but which is also ideally placed to contribute towards the Black Country’s
housing shortfall.