BASE HEADER

No

ID sylw: 106343

Derbyniwyd: 27/02/2025

Ymatebydd: Neil Francis

Your consultation states that, for the Greater Birmingham and Black Country HMA, there is evidence of a significant shortfall between housing requirements and land supply. However, the overall scale of the shortfall has not been collectively quantified beyond 2031 since the GBBCHMA Strategic Growth Study (2018). A study refresh is required to re-evaluate the housing shortfall considering more recent evidence and policy. Council officers meet regularly with counterparts from other Councils and with various stakeholders in both the Coventry & Warwickshire and Greater Birmingham & Black Country Housing Market Area to discuss cross boundary issues. Until there is greater certainty regarding the quantum of unmet needs from neighbouring housing market areas, it is premature to allocate reserve housing sites.
Your consultation is not clear on this position. Whilst you do not specifically say that site SG24 is identified to meet the needs of housing in Birmingham under the duty to cooperate, the URL on the interactive map takes the user directly to this section of the consultation which suggests this may be a consideration. Under the new NPPF, the housing figures for Birmingham have reduced from 7,174 to 4,448. Whilst Solihull was previously showing the provision of 2,000 houses to meet the needs of Birmingham under the duty to co-operate, there is no evidence to suggest that will now be the case, especially given the reduced number for Birmingham.
It is also clear from your consultation that the overall scale of any shortfall has not been collectively quantified beyond 2031 since the GBBCHMA Strategic Growth Study (2018). You also indicate that a study refresh is required to re-evaluate the housing shortfall considering more recent evidence and policy. Until there is a greater certainty regarding the quantum of unmet needs from neighbouring housing market areas it is premature to allocate reserve housing sites.
In addition, I would also note that there are public walkways over the proposed sites which could potentially constrain their development.