Object
Preferred Options November 2021
Representation ID: 1029
Received: 13/12/2021
Respondent: Hallam Land Management
Agent: Acres Land & Planning
It would be more logical to use 2018 GL Hearn/Wood report for starting point to choosing sites as this has been prepared at a strategic level using objective criteria for entire conurbation thus removing elements of subjectivity.
Concerns that the infrastructure led strategy is driving choice of GB sites over more sensitive sites with the consequence that more sensitive, logical GB sites that align better with GB policy are omitted.
The Strategy is over-reliant on a small number of large sites such as Strategic Allocations at Cross Green (Policy SA2), Linthouse Lane (SA3) and land east of Bilbrook which may be slow to delivery and thus undermine targets.
GBBCHMA shortfall appears to have increased since shortfallw as initially identified. Recent studies by Barton Willmore and Turley have shown much higher levels of housing shortfall that has not been tested by the Council. 4,000 homes offered may not be enough.
The offer of 4,000 is minimal and there should be discussion as to varying levels of housing provision. The Standard method is also set to be reviewed with housing provision diverted to areas promoted for "levelling up" such as the midlands - thus increasing housing targets. This should be kept under review and change if necessary.
Consent for SRFI at Four Ashes and growth of i54 is likely to boost housing need beyond Standard Method target. Greater pressure for larger (and higher quantity of) homes due to working from home patterns continued post-Covid.
Assessment for permission lapses (eg. 5-10%) needs to be had and an allowance for sites granted/delivered outside of plan period.
Not content with level of housing allocated for Codsall/Bilbrook as its level of provision has fallen back proportionately compared to Penkridge and some other settlements since the Issues and Options plan.
Do not support the proposed direction of growth on the edge of Bilbrook/Codsall which does not conform to advice in Greater Birmingham HMA Study where growth would occur to the north of Codsall. The Council's proposed distribution conflicts with the technical advice on GB criteria.