Draft Regulation 18 Sandwell Local Plan

This letter is submitted by Gladman Developments Ltd (Gladman) in response to the Sandwell Draft Local Plan Regulation 18 consultation. It should be read in conjunction with the ‘Falling Even Shorter: an updated review of unmet housing needs in the Greater Birmingham and Black Country Housing Market Area’ (prepared by Turley on behalf of a consortium of parties, including Gladman) which is appended to this letter.

Gladman are supportive of the preparation of a new Local Plan for Sandwell. The current Black Country Core Strategy was adopted in 2011, while the Site Allocations and Delivery Development Plan Document was adopted in 2012. These pre-date substantive changes in national planning policy and guidance and changes in local circumstances and priorities further justify the need for a new Local Plan. This includes, notably, the significant challenges associated with meeting the identified growth needs of the borough and across the wider Greater Birmingham and Black Country Housing Market Area.

At the stage we do not wish to make specific comments on policy requirements; however, we reserve the right to do so in future consultations. Nonetheless, it is important to remind the Council that any policy requirements relating to, for example, climate change, biodiversity net gain and open space provision, particularly where a higher standard than that required by current or emerging legislation is sought, must be robustly evidence based and not make development and the whole plan unviable.

The primary issues which this representation focuses on is the provision of housing need, engagement and cooperation with neighbouring authorities and Green Belt.

Gladman are concerned that the Local Plan only proposes to deliver 11,167 homes between 2022- 2041 against an identified housing need of 29,773 homes, representing a shortfall of 18,606 homes, over 60%. This is a critically low level of housing provision in a context where there is an estimated shortfall of up to 40,676 homes across the Greater Birmingham and Black Country HMA (GBBCHMA) (See Appendix 1).
Every opportunity to meet these identified housing needs must be explored to ensure that real people are provided with the housing they need.

With this in mind, Gladman strongly disagree with the Council’s position on Green Belt in the borough where they have considered that there are no exceptional circumstances which would justify amending the current boundaries and releasing any areas of green belt for new development. Noting that the shortfall of deliverable land for housing does not outweigh the need to maintain openness and permanence of the Green Belt within Sandwell (Paragraph 3.85 Draft Local Plan).

The Local Plan presents a critically low housing land supply that does not come close to meeting the identified housing needs of the borough. Seeking to deliver the homes people desperately need, including affordable homes, in the location they arise represents a very exceptional circumstance in which to review the Green Belt. In addition, it is clear that the council have sought to explore all other reasonable options for meeting its housing needs and therefore a review of the Green belt must be undertaken to understand the most appropriate locations to release land from the Green belt and deliver its development needs1.

While it is true that not all areas of Green Belt will represent an appropriate location to deliver growth, the Council should undertake a thorough review to understand how all parcels of the Green Belt perform against the five purposes set out in the Framework. Without this information it is impossible to determine whether Green Belt boundaries could be appropriately amended to accommodate a proportion of the significant shortfall in housing supply.

Finally, it is critical that the Council engages with neighbouring authorities and those within the GBBC HMA in order to ensure the delivery of all the borough’s housing and growth needs. The Council has not presented a Statement of Common Ground on this issue nor published a Duty to Cooperate Statement. The Council must pro-actively engage with the other authorities as a matter of urgency to agree a distribution of housing shortfall, following further work on housing evidence and Green Belt review studies, to ensure that these needs are met. This both a legal, Duty to Cooperate and soundness issue.

This letter is submitted by Gladman Developments Ltd (Gladman) in response to the Sandwell Draft Local Plan Regulation 18 consultation. It should be read in conjunction with the ‘Falling Even Shorter: an updated review of unmet housing needs in the Greater Birmingham and Black Country Housing Market Area’ (prepared by Turley on behalf of a consortium of parties, including Gladman) which is appended to this letter.

Gladman are supportive of the preparation of a new Local Plan for Sandwell. The current Black Country Core Strategy was adopted in 2011, while the Site Allocations and Delivery Development Plan Document was adopted in 2012. These pre-date substantive changes in national planning policy and guidance and changes in local circumstances and priorities further justify the need for a new Local Plan. This includes, notably, the significant challenges associated with meeting the identified growth needs of the borough and across the wider Greater Birmingham and Black Country Housing Market Area.

At the stage we do not wish to make specific comments on policy requirements; however, we reserve the right to do so in future consultations. Nonetheless, it is important to remind the Council that any policy requirements relating to, for example, climate change, biodiversity net gain and open space provision, particularly where a higher standard than that required by current or emerging legislation is sought, must be robustly evidence based and not make development and the whole plan unviable.

The primary issues which this representation focuses on is the provision of housing need, engagement and cooperation with neighbouring authorities and Green Belt.

Gladman are concerned that the Local Plan only proposes to deliver 11,167 homes between 2022- 2041 against an identified housing need of 29,773 homes, representing a shortfall of 18,606 homes, over 60%. This is a critically low level of housing provision in a context where there is an estimated shortfall of up to 40,676 homes across the Greater Birmingham and Black Country HMA (GBBCHMA) (See Appendix 1).
Every opportunity to meet these identified housing needs must be explored to ensure that real people are provided with the housing they need.

With this in mind, Gladman strongly disagree with the Council’s position on Green Belt in the borough where they have considered that there are no exceptional circumstances which would justify amending the current boundaries and releasing any areas of green belt for new development. Noting that the shortfall of deliverable land for housing does not outweigh the need to maintain openness and permanence of the Green Belt within Sandwell (Paragraph 3.85 Draft Local Plan).

The Local Plan presents a critically low housing land supply that does not come close to meeting the identified housing needs of the borough. Seeking to deliver the homes people desperately need, including affordable homes, in the location they arise represents a very exceptional circumstance in which to review the Green Belt. In addition, it is clear that the council have sought to explore all other reasonable options for meeting its housing needs and therefore a review of the Green belt must be undertaken to understand the most appropriate locations to release land from the Green belt and deliver its development needs1.

While it is true that not all areas of Green Belt will represent an appropriate location to deliver growth, the Council should undertake a thorough review to understand how all parcels of the Green Belt perform against the five purposes set out in the Framework. Without this information it is impossible to determine whether Green Belt boundaries could be appropriately amended to accommodate a proportion of the significant shortfall in housing supply.

Finally, it is critical that the Council engages with neighbouring authorities and those within the GBBC HMA in order to ensure the delivery of all the borough’s housing and growth needs. The Council has not presented a Statement of Common Ground on this issue nor published a Duty to Cooperate Statement. The Council must pro-actively engage with the other authorities as a matter of urgency to agree a distribution of housing shortfall, following further work on housing evidence and Green Belt review studies, to ensure that these needs are met. This both a legal, Duty to Cooperate and soundness issue.

This letter is submitted by Gladman Developments Ltd (Gladman) in response to the Sandwell Draft Local Plan Regulation 18 consultation. It should be read in conjunction with the ‘Falling Even Shorter: an updated review of unmet housing needs in the Greater Birmingham and Black Country Housing Market Area’ (prepared by Turley on behalf of a consortium of parties, including Gladman) which is appended to this letter.

Gladman are supportive of the preparation of a new Local Plan for Sandwell. The current Black Country Core Strategy was adopted in 2011, while the Site Allocations and Delivery Development Plan Document was adopted in 2012. These pre-date substantive changes in national planning policy and guidance and changes in local circumstances and priorities further justify the need for a new Local Plan. This includes, notably, the significant challenges associated with meeting the identified growth needs of the borough and across the wider Greater Birmingham and Black Country Housing Market Area.

At the stage we do not wish to make specific comments on policy requirements; however, we reserve the right to do so in future consultations. Nonetheless, it is important to remind the Council that any policy requirements relating to, for example, climate change, biodiversity net gain and open space provision, particularly where a higher standard than that required by current or emerging legislation is sought, must be robustly evidence based and not make development and the whole plan unviable.

The primary issues which this representation focuses on is the provision of housing need, engagement and cooperation with neighbouring authorities and Green Belt.

Gladman are concerned that the Local Plan only proposes to deliver 11,167 homes between 2022- 2041 against an identified housing need of 29,773 homes, representing a shortfall of 18,606 homes, over 60%. This is a critically low level of housing provision in a context where there is an estimated shortfall of up to 40,676 homes across the Greater Birmingham and Black Country HMA (GBBCHMA) (See Appendix 1).
Every opportunity to meet these identified housing needs must be explored to ensure that real people are provided with the housing they need.

With this in mind, Gladman strongly disagree with the Council’s position on Green Belt in the borough where they have considered that there are no exceptional circumstances which would justify amending the current boundaries and releasing any areas of green belt for new development. Noting that the shortfall of deliverable land for housing does not outweigh the need to maintain openness and permanence of the Green Belt within Sandwell (Paragraph 3.85 Draft Local Plan).

The Local Plan presents a critically low housing land supply that does not come close to meeting the identified housing needs of the borough. Seeking to deliver the homes people desperately need, including affordable homes, in the location they arise represents a very exceptional circumstance in which to review the Green Belt. In addition, it is clear that the council have sought to explore all other reasonable options for meeting its housing needs and therefore a review of the Green belt must be undertaken to understand the most appropriate locations to release land from the Green belt and deliver its development needs1.

While it is true that not all areas of Green Belt will represent an appropriate location to deliver growth, the Council should undertake a thorough review to understand how all parcels of the Green Belt perform against the five purposes set out in the Framework. Without this information it is impossible to determine whether Green Belt boundaries could be appropriately amended to accommodate a proportion of the significant shortfall in housing supply.

Finally, it is critical that the Council engages with neighbouring authorities and those within the GBBC HMA in order to ensure the delivery of all the borough’s housing and growth needs. The Council has not presented a Statement of Common Ground on this issue nor published a Duty to Cooperate Statement. The Council must pro-actively engage with the other authorities as a matter of urgency to agree a distribution of housing shortfall, following further work on housing evidence and Green Belt review studies, to ensure that these needs are met. This both a legal, Duty to Cooperate and soundness issue.