Object

Representation ID: 1433

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Council has not proposed an uplift to the minimum standard method figure to meet local needs nor has the Strategic Housing Market Assessment (‘SHMA’) May 2021 assessed the requirement for an uplift. Without a buffer, we do not consider that the plan has been positively prepared in an aspirational way (NPPF paragraph 16) nor does it support the Government’s
objective of significantly boosting the supply of homes (NPPF paragraph 60).
The NPPF also requires plans to “be able to demonstrate that Green Belt boundaries will not need to be altered
at the end of the plan period” (paragraph 143). Given our comments above, we consider that additional Green
Belt land will be required within the plan period so therefore the plan does not accord with the NPPF.

Therefore, additional sites should be identified within the District in order to meet these additional housing needs. We consider that our client’s land (site reference 500) forms a logical extension to proposed Strategic Allocation SA1 and should be considered for a residential allocation to assist the Council in meeting their housing needs.
We question why these SoCGs are not being drafted and regularly updated now, as recommended by the PPG (Reference ID: 61-020-20190315).