Object

Representation ID: 4938

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The PPG is clear that the standard method sets the minimum housing need and does not produce a housing requirement figure (Reference ID: 2a-002-20190220); and there may be circumstances where a higher requirement figure is appropriate, for example, meeting unmet HMA needs or previous levels of housing under-delivery (Reference ID: 2a-010-20201216). Although the plan does include a contribution towards the HMA shortfall which the Council may consider is a suitable buffer, the 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 and update October 2022 assessed the requirement for an uplift for economic growth aspirations. Without a buffer, we do not consider that the plan has been positively prepared in an aspirational way (NPPF paragraphs 16 and 35) nor does it support the Government’s objective of significantly boosting the supply of homes (NPPF paragraph 60).

Barratt therefore supports the proposed approach to contribute towards the GBBCHMA shortfall but objects to the 4,000 dwelling figure.

Paragraph 5.15 of the plan states that there is emerging evidence demonstrating a significant shortfall across the GBBCHMA but the “exact extent is not currently known”. Barratt agrees that the distribution of the housing shortfall across the HMA authorities has not been agreed, nor is it known when it will be so the Council cannot fully justify that 4,000 dwellings is a reasonable contribution. Particularly given that there are now additional significant housing shortfalls arising from the Black Country (circa 28,000 dwellings) and Birmingham (circa 78,000 dwellings) and yet the 4,000 dwelling contribution has not been increased from the Preferred Options Stage to reflect the changing circumstances. It is also unclear how SSDC propose to distribute the 4,000 dwellings with the authorities generating the shortfall. The District has a strong connectivity with the GBBCHMA and the Birmingham conurbation so is well placed to accommodate more of the shortfall than other authorities in the GBBCHMA. Barratt therefore considers that in order for the plan to be positively prepared (NPPF paragraph 35), SSDC should be proposing more than 4,000 dwellings towards the significant HMA shortfall.
Table 8 in the local plan sets out how housing growth is proposed to be distributed across the District. Circa 16.8% of the total housing growth proposed is to be delivered in Codsall / Bilbrook (679 new dwellings proposed, 584 dwellings from safeguarded land and 462 dwellings from existing permissions). As arguably the most sustainable settlements in the District, it is considered that more growth should be directed to these settlements. Additionally, the train stations within the settlements make this location highly accessible to the GBBCHMA.

Challenge windfall allowance.

Within the Housing Growth in Locality 4 (Codsall / Bilbrook) section of the plan, it states that “the level of growth to be delivered is also aligned to the level of growth advised by the Education Authority to deliver an appropriately sized First School in this location whilst avoiding creating capacity issues at the Middle and High School level”. The NPPF (paragraphs 20 and 34) requires plans to set out the level of infrastructure (including education) that is required to support the amount of growth planned. Barratt therefore do not support SSDC’s approach that education capacity should limit the amount of growth being target to the most sustainable settlements in the District as it is not consistent with national policy. If school capacity issues have been identified then this should be addressed now through plans for expansion of the existing schools or the allocation land for education within the plan.