Sandwell Local Plan - Reg 19 Publication

Comment

Representation ID: 1368

Received: 05/11/2024

Respondent: lichfield District Council

It is noted within Policy SEC1 that there is an employment need of 212ha in Sandwell. The total identified supply is 42ha, leaving a significant shortfall of 170ha. This is proposed to be exported through the Duty to Cooperate to authorities within the Functional Economic Market Area (FEMA). LDC supports SMBC in meeting its own needs through the allocation of new employment sites and ongoing Duty to Cooperate discussions with BC FEMA authorities.

The now withdrawn Lichfield District Local Plan 2043 identified that there is a relatively limited supply of employment sites within Lichfield District and that the council was unable to assist authorities in respect of any unmet employment needs.

Comment

Representation ID: 1369

Received: 05/11/2024

Respondent: lichfield District Council

Paragraph 7.75 indicates a need for 14 pitches over the plan period up to 2041. The SLP has allocated sites for 10 pitches, resulting in a shortfall of 4 pitches. LDC supports SMBC’s approach, as outlined in paragraph 7.78, to continue seeking new or expanded public sites to address this unmet need and to respond positively to windfall proposals.

As noted above, LDC’s Local Plan is in the early stages of preparation and as such has not yet established the Gypsy and Traveller Needs to be planned for. However, both the adopted Local Plan and withdrawn Local Plan were not able to identify sufficient sites to meet the need at the time. Indeed, Lichfield District Council previously wrote to neighbouring authorities to ascertain whether they could assist in meeting this unmet need.

Comment

Representation ID: 1370

Received: 05/11/2024

Respondent: lichfield District Council

The comments below focus on the primary area of concern from Lichfield District Council’s perspective which relates to unmet housing need arising from Sandwell and the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA).

LDC along with SMBC have been an active member of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) officers’ group and have contributed to discussion relating to the delivery of unmet need within the housing market area, including the ongoing work to update the 2018 Strategy Growth Study.

LDC notes that the consultation on the NPPF included proposals to change the ‘standard method’ which is used to calculate an areas Local Housing Need. Under the proposed changes SMBCs LHN would decrease by 3%, whilst LDC’s will increase significantly (by 160%). As such, it is important that as both authority’s plans progress, they have regard to the relevant housing requirement and consider the implications for both councils should the proposed changes to the standard method be implemented by Government having regard to any transitional arrangements.

It is noted that at paragraph 3.13, the SLP identifies that there is a total local housing need of 26,350 and that the SLP aims to allocate sites to deliver 10,434 of these homes. As such, the plan proposes a supply of just over 39% of its total need. This shortfall when combined with further potential shortfalls within the housing market area is significant. There is concerned that the ‘balanced green growth’ may not have thoroughly explored all opportunities to increase housing delivery within its administrative area, including reviewing Green Belt boundaries and increasing densities. As such, LDC considers that in the context of this unmet need SMBC should have undertaken a review of its Green Belt boundaries to order to understand whether changes to the boundary could be made to assist in meeting its own needs. SMBC will need to full evidence and justify that they have explored and exhausted all options to accommodate growth within their administrative area. Furthermore, SMBC should identify any further potential sources of housing land supply and ensure that all development opportunities within its administrative area are maximised prior to any shortfall being exported to other areas.

LDC notes that Policy SDS1 states that housing and employment needs that cannot be accommodated within the borough will be exported to neighbouring local authority areas. LDC wishes to stress that this should be based on a clear understanding of the functional and physical relationships within the functional economic area, including migration and commuting patterns, to ensure needs are met as close as possible to where they arise.

Comment

Representation ID: 1371

Received: 05/11/2024

Respondent: lichfield District Council

Paragraph 3.99 states that SMBC has taken the decision not to review Green Belt boundaries within the SLP. This follows changes which were made to the NPPF in December 2023 which allowed authorities to determine whether they would undertake a review of the Green Belt. It is noted that following the general election in July 2024 government have consulted upon further changes to the NPPF which could reverse the changes made in December 2023. Should these changes come into force this would require authorities to undertake a Green Belt review should they not be able to accommodate all their housing within their administrative boundaries, subject to any transitional arrangements.

Whilst LDC recognises the highly constrained nature of the land supply in Sandwell, it is considered that SMBC should seek to accommodate as much housing within its own administrative boundary as possible to meet its own needs, including maximising densities and considering whether Green Belt release could assist in accommodating need. There are limited areas beyond the Green Belt within the GBBCHMA and should all authorities determine not to consider their Green Belt boundaries this will significantly limit the ability of the authorities to address the shortfall. Indeed the delivery of homes within SMBC’s area would ensure the homes are delivered closest to where the need arises.

SMBC will therefore need to fully justify and evidence that there are no exceptional circumstances that exist that could justify potential Green Belt release. Given the significant level of unmet need and noting the benefits of delivering need closes to where it arises, it may be that such circumstances exist.