Draft Black Country Plan

Comment

Representation ID: 18417

Received: 05/10/2021

Respondent: Redditch Borough Council

Consultation on Draft Black Country Local Plan
Redditch Borough Council (RBC) welcomes the opportunity to comment on the above document and
to continue to engage constructively with the Black Country Plan in the best interests of positive planmaking. The response below has been written in consultation with the Council’s Portfolio Holder for
Planning, Economic Development, Commercialism and Partnerships and is due to be reported
to Members at Executive Committee on 26th October.

Firstly, we note and support the Black Country Authorities’ intention at Paragraph 1.10 of the Draft
BCP to draft and agree Statements Of Common Ground with all relevant bodies on Duty to Co-operate
issues at the Plan’s Publication Stage. RBC submitted its “Duty to Engagement Proforma” in 2018
which recognised the challenges of meeting the wider housing needs of the Birmingham and Black
Country Housing Market Area. RBC reiterated in this Proforma that this needs to be based on fully
evidenced scenarios and progressed through development planning work by the local authorities. We
continue to emphasise this view.

Comment

Representation ID: 18418

Received: 05/10/2021

Respondent: Redditch Borough Council

Consultation on Draft Black Country Local Plan
Redditch Borough Council (RBC) welcomes the opportunity to comment on the above document and
to continue to engage constructively with the Black Country Plan in the best interests of positive planmaking. The response below has been written in consultation with the Council’s Portfolio Holder for
Planning, Economic Development, Commercialism and Partnerships and is due to be reported
to Members at Executive Committee on 26th October.

Secondly, we recognise the significant shortfall of 28,239 homes and 210 hectares of employment
land currently identified within the Draft BCP. In particular Paragraph 3.27 is noted, which places
emphasis on the Black Country Authorities’ support to neighbouring authorities in bringing forward
land for housing and employment that “sits adjacent to the existing administrative boundaries.”
As currently set out in the Draft Plan, it is RBC’s interpretation that there are unlikely to be potential
requirements for RBC to be involved in cross boundary discussions under the Duty to Co-operate with
regard to meeting a proportion of the Black Country’s housing and employment needs. This is because
the authorities do not share any common boundaries.