Object

Representation ID: 4975

Received: 19/12/2022

Respondent: FGD Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Planning Practice Guidance (‘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). We therefore support the Council’s proposal to contribute towards the GBBCHMA
shortfall but have concerns over the ‘4,000’ dwellings figure.
Since
the Preferred Options consultation, it is now apparent that there is also a significant additional shortfall arising
from Birmingham (circa 78,000 dwellings and 73.6ha of employment land). However, even with this significant
shortfall increase, SSDC has not sought to increase their contribution and it remains at 4,000 dwellings.
We consider that the proposed contribution towards the GBBCHMA housing and employment shortfalls, should
be increased to reflect the evidence published more recently on the significant increase to the shortfall across
the plan period.
Paragraph 5.19 of the Publication Plan sets out changes made to the housing growth strategy as a result of
previous comments made to the Preferred Options consultation. SSDC has now sought to reduce the amount
of growth allocated to the western edge of the Black Country. SSDC state that this reflects “the relatively limited
unmet need arising from Dudley Metropolitan Borough, which also holds significant Green Belt site options in
this area within its own administrative boundary as set out in the GBBCHMA Strategic Growth Study”. We do
not support this statement. Even though Dudley claim to be able to meet their own needs, there is still a
significant shortfall arising from across the Black Country (which Dudley is a part of) and Birmingham which
SSDC should be seeking to accommodate in sustainable locations across the district. Land immediately
adjacent to the western edge of the Black Country, such as site reference 577, is considered to be highly
suitable and accessible to the Black Country to meet the significant unmet housing and employment needs.